Turnkey Trading Partners is committed to providing NFA Members with the resources they need to meet their regulatory obligations as efficiently as possible. The following information was published by NFA and has been summarized below for easier consumption:

Annual Updates

On an annual basis (every 365 days minimum) All NFA Members must:

Ongoing updates

On an ongoing basis, all NFA Members must:

  • Update the Annual Questionnaire in the event of a material change to operations.
  • Keep Form 7-R up-to-date; among other information this form includes the firm’s address, contact information and listed principals and can be accessed using NFA’s Online Registration System(ORS).
  • CPO and CTA Members must compute financial ratios using the accrual method of accounting and in accordance with U.S. generally accepted accounting principles or another internationally recognized accounting standard.
  • As applicable; CPO and CTA Members must have a disclosure document that is current within the preceding 12 months which has been filed and accepted by NFA.
  • Firms engaging in virtual currency activities must provide appropriate disclosures to their customers.
  • Only firms whose regulated activity is limited to OTC swaps may claim to be Swaps Exclusive on the Form 7-R. Otherwise, the firm’s APs must pass the Series 3 exam. For Swaps Exclusive firms NFA recently updated its obligations for Swap AP registration.
  • FCM and IB Members must ensure that their Anti-Money Laundering Programs include procedures for conducting ongoing customer due diligence and verifying beneficial owners for legal entity customers as outlined in Interpretive Notice 9071.
  • FCMs, IBs and those CPOs who choose to have AML programs which rely on other financial institutions to identify and verify beneficial owners of legal entity customers must establish or update existing contracts to incorporate the requirements that will be performed by the other financial institution.

Direct Links to NFA Ongoing Regulatory Obligations

Introducing brokers (IB)

Commodity trading advisors (CTA)

Commodity pool operators (CPO)

Futures commission merchants (FCM)

Forex dealer members (FDM)

If you need assistance with any NFA requirements, please contact Turnkey at 312-324-0040 or Click Here to submit on online request.  Not a subscriber to our newsletter? You’re missing out! Sign up and request to receive more information here.