As the unprecedented year of 2020 comes to a close, staff will begin leaving for holiday vacation and compliance will be forgotten.  Turnkey Trading Partners always likes to remind our clients to consider annual compliance deadlines and obligations.  This year saw both the Commodity Futures Trading Commission (“CFTC”) as well as National Futures Association (“NFA”) roll out a number of new compliance and regulatory changes.  They also increased enforcement efforts and have been significantly more active with audits than they have in previous years.

2020 NFA Annual Obligations

  1. Update/Review Compliance Manual as applicable
  2. Consider sending annual BASIC notice to customers
  3. Annual privacy notice to customers (consider changes to policy)
  4. For IB’s update and obtain New FCM AML reliance agreements.
  5. Complete NFA’s Annual Questionnaire  
  6. Pay NFA Dues and update all registration information
  7. Complete NFA’s Self-Examination Questionnaire  for main office and branch offices
  8. Ensure branch and GIB locations have been audited within the calendar year (call Turnkey for help!)
  9. Conduct all trainings necessary such as Anti-Money Laundering (“AML”), Ethics, Cybersecurity, Identity Theft training for relevant employee
  10. Test your Cyber Security and Disaster Recovery Plan and make any necessary adjustments.

2020 Year In Review

If you have not done so sign up for Turnkey’s Newsletter which is sent monthly. We don’t sell or share customer information and we provide industry leading CFTC and NFA compliance content each month. The following are articles we have written in 2020 who’s topics range across new approaches from regulators, how Covid-19 has impacted your compliance obligations and unprecedented market events:

CFTC/NFA Members Victims of Corporate Identity Theft

CFTC,NFA, CME – Written Supervisory Procedures

CTA-PR, CPO-PQR Accounting and Performance Reporting

NFA Virtual Audits – A Follow Up

CFTC and NFA Compliance: Covid’s “New Audit Normal”

New NFA Self Exam: Subtle Changes….BIG Implications 

Impact of Negative Oil Prices: CFTC/NFA Market Participant Thoughts 

NFA Swaps Proficiency Test: An Inside Look

World Stops; CFTC & NFA Compliance March On

CTA Performance Reporting and Allocation Variance 

NFA Trade Execution Audit: Are you Prepared?

Before taking holiday, vacation be sure you use the last few weeks of the year to complete your annual compliance obligations.  If you have any questions or concerns with your compliance program, please contact Turnkey today via (312) 324-0040 or by clicking here. Our team can conduct mock audits for your firm and fully assist with ensuring 2021 is your best year of compliance yet!