Relief from the On-Site Annual Inspection of Branch Offices and Guaranteed IBs

Due to COVID-19, NFA understands that it may difficult for Members to conduct on-site inspections at branch offices and guaranteed IBs this year. Therefore, although Members must conduct the required annual inspection of each branch office and guaranteed IB by December 31, 2020, firms may conduct these inspections remotely.

CTA-PR, CPO-PQR Accounting and Performance Reporting

Recently, Turnkey has noticed that during NFA audits, examiners are starting to ask more about CTA and CPO accounting methodology. In other words, they want to understand book keeping process and record keeping habits. NFA auditors are also regularly asking firms about accrual-based accounting versus cash-based accounting.

Expiration of Temporary No-Action Relief from the Requirement to Submit a Fingerprint Card with Form 8-R

Given the widespread, if restricted, reopening of businesses and services in most parts of the country, and the availability of law enforcement offices to persons needing to have fingerprints taken, DSIO now believes that the blanket relief provided under Staff Letters 20-16 and 20-20 is no longer urgently needed. Accordingly, that general relief will be permitted to expire September 30.