Common NFA Audit Deficiencies: Summer 2024 Edition

Turnkey periodically shares common audit deficiencies observed in National Futures Association (“NFA”) exams. Typically supporting 10 to 15 audits simultaneously, we gain insight into the areas the NFA emphasizes most….

Read More

Ethics Training: Clearing the Fog of Uncertainty

Ethics training remains a supervisory obligation under NFA’s Compliance Rules 2-9 and 2-36. Despite the 2001 repeal of specific regulations, firms are still required to uphold high ethical standards and regularly update their training to reflect changes in industry standards, technology, and regulations. This has led to confusion about the ethics training requirements for NFA member firms. The team at Turnkey Trading Partners (“Turnkey”) has observed uncertainty regarding who needs to complete ethics training and the frequency with which it should be conducted.