CFTC, NFA Third Party Service Provider Obligations Apr 21, 2021 In February, NFA adopted an Interpretive Notice entitled “NFA Compliance Rules 2-9 and 2-36: Members’ Use of Third-Party Service Providers” which will become effective September 30, 2021. This notice is the first time NFA has publicly laid out its expectations for how member firms outsource certain of their company functions. It is important to recognize that NFA has not prohibited any registrant or member firm from outsourcing any function. Rather, they have set standards for what they believe reasonable outsourcing risks should and could look like.