Sep 22, 2025 At Turnkey Trading Partners, one of our annual traditions going into the fourth quarter is to provide clients and industry colleagues with a compliance “check-list.” This serves two purposes: first, to keep everyone abreast of the latest regulatory developments; and second, to encourage firms to reevaluate their compliance programs before year-end. With the pace of regulatory change showing no signs of slowing, this exercise is more important than ever. Throughout 2025, both the Commodity Futures Trading Commission (CFTC) and the National Futures Association (NFA) have introduced meaningful new rules and interpretations. At the same time, they continue to intensify enforcement efforts—particularly around communications supervision, cybersecurity readiness, and third-party service provider oversight. With these developments in mind, we urge you to use this opportunity to review the following checklist of compliance obligations. If you have questions—or if you are unsure whether your firm is meeting its requirements—Turnkey is here to help. General NFA Annual Compliance Obligations Review and update your Compliance Manual (at least annually). Send annual privacy notice to customers (consider policy changes). Introducing Brokers (IBs): Update and obtain new FCM AML reliance agreements if applicable. Complete the NFA Annual Questionnaire (must be filed by an AP/Principal). Pay NFA dues and update registration via Form 7-R (firm); confirm no changes for APs via Form 8-R (individual). Complete the NFA Self-Examination Questionnaire for main and branch offices; document and attest. Complete all applicable Self-Examination Questionnaire Appendices. Document, supervise, and evaluate APs working remotely from main office locations. Audit all branch and Guaranteed Introducing Broker (GIB) locations within the calendar year (Turnkey can help). Ensure GIB and branch offices are visited onsite at least once every other year. Conduct employee training: AML, Ethics, Cybersecurity, Identity Theft, and any additional regulatory topics. Test Cybersecurity and Business Continuity/Disaster Recovery (BCDR) Plans and make updates as needed. Review Third-Party Service Provider (TPSP) policies and update vendor profiles annually. Reassess AML program; if required, complete independent AML audit. Review website and promotional materials; document approvals and maintain records. Commodity Pool Operators (CPOs): Update PPM annually or upon material changes. Commodity Trading Advisors (CTAs): Update disclosure documents annually or upon material changes. Document reviews of ongoing electronic and written communications. Retain communication records to support supervisory reviews. Conduct communications reviews at least monthly, as expected by NFA. If you have any questions or need assistance strengthening your compliance program, contact Turnkey at (312) 324-0040 or click here. Our team can conduct mock audits, policy reviews, and program evaluations to help ensure that 2025 ends—and 2026 begins—as your strongest year of compliance yet.