By: Turnkey Trading Partners

Turnkey Trading Partners has years of experience managing compliance programs for FCM, IB, CTA, and CPO customers. We also support dozens of regulatory examinations and inquiries each calendar year. Through our engagement with industry regulators, Turnkey staff have identified a trend begin to emerge in the area of training and ongoing education. Although nothing definitive has been published in this area, the new prevailing view of examiners seems to be that most firms are not doing enough to educate and train their staff.  Evidence of this can be seen in that both the CFTC and NFA are more frequently citing deficient ongoing education or training programs in their disciplinary actions. Similarly, industry exchanges are also now regularly inquiring about how industry participants were trained in various rules, manipulative behaviors, and other brokerage and trading areas.  Unfortunately, far too often registrants don’t have a sufficient response to these inquiries. The reason? For the last thirty years training has been viewed as a “check the box” exercise by most of the industry.

Crux of the Problem

Turnkey first began to identify the above problem in late 2019. Since the Covid-19 pandemic forced staff to work from home, regulators have only increased their scrutiny in this area. Most CFTC registered firms are only mandated to provide Ethics training, Cyber-Security training, and Anti-Money Laundering (AML) training. The conventional thinking has also been that Ethics would be provided once every three years, with cyber and AML being provided annually. Staff members take these courses online, race through the material, send certificates back to the compliance department, and never think about the coursework again.

Another issue that both Turnkey and regulators have identified is that training providers develop content which ages very poorly. The best vendors may develop new content annually but for the most part training materials remain largely static for the entire calendar year. Training and educational materials must be dynamic. To be effective they have to evolve over time. Regular and timely updates should be provided to staff as they occur. Industry best practices, regulatory changes, current disciplinary trends, and other general industry news must be communicated as its developing. Waiting a year or more to communicate this content isn’t helpful to anyone.

Lastly, a vast majority of industry registrants don’t provide the correct content. As an example, although all registrants are responsible for protecting customer personal identifying information (PII), very few ever offer identity theft training. Why? Similarly, all CFTC registered firms either broker, trade, or offer investment advice in commodity interest products and/or markets. Although the sole purpose of being registered is to engage in this way, few firms offer any training or educational material about market regulations, behavior, or appropriate trading conduct. Why?  Similarly, in 2022 does it really make sense to offer ethics training to staff one time every three years? Is this frequent enough for staff to be reminded of their obligations to conduct themselves accordingly within the space?  Do any of the following examples really make practical sense? Regulators are starting to understand that culturally the industry has been taught to race through training, check a box, and move on. This simply isn’t good enough anymore.

A New Approach Needed and Developed

In order to best remedy the above concerns for our customers, starting in 2021, Turnkey began to rethink how training could and should be offered to the industry. Throughout this process we considered what our customers liked and didn’t like about existing training products. We also evaluated what regulators had been saying about existing training products and industry approaches.  Ultimately, we decided to develop our first ever ongoing education platform called “Turnkey Training.”  Our team worked diligently to put forward a best-in-class product that aims to change the way training is viewed throughout the industry. So far, both regulators and customers have overwhelmingly welcomed our approach. Gone are the areas of training that don’t make sense. Now included are areas of training that firms desperately need to have a well-educated and supported team. Turnkey’s product offers more than just “check the box” training. We have implemented a number of industry first features, some of which follow in the paragraphs below.

All Training Included

Turnkey training was designed to be administered to everyone on your team. There is no practical or good reason that staff working for a brokerage or trading firm should not have at least a cursory knowledge of the industry.  In our experience, we have found our customers confused about what training to purchase, for whom, and at what time. We have made that incredibly easy for our users.  Turnkey’s training product is set up with “Core” curriculum. This curriculum includes what we believe should be required training for all registered firms.  Our training includes AML, Ethics, Cyber Security, Identity Theft, and Market Regulations.  We then have other materials which we consider “+” content. This content is included for free. Once someone is subscribed to the training product all core training is provided at the same price within our training dashboard. Users can then complete all training or just the training that they are required to take under their respective supervisory and compliance programs. Quarterly updates ensure that no content remains static and grows stale as the industry changes.

Annual Subscription

As a rule, CFTC registered, NFA member firms must complete ongoing training on an annual basis. Turnkey has found that most training providers do not sell training in a way that harmonizes with this obligation. They sell training one course at a time for one time use.  Our training products are sold on an annual subscription basis and include everything for the entire year.  This allows Turnkey Training to assist its customers to better harmonize training dates and improve the probability that training is not administered late. It also allows our training products to be available to your team members whenever they may want to revisit material – not just one time, once a year.

Consider Switching Before It Is Too Late

In our view it is only a matter of time before industry regulators push even harder on the ongoing education and training gap in the industry.  Turnkey would love for you to join us in redefining training within the CFTC and NFA regulatory space. We believe our product is one of the best in the industry. We’re confident you’ll enjoy our new offering and we’d love to have you try it!  To learn more about Turnkey Training please visit our training and education page here.  To purchase training directly please go here.  If you have questions, please contact us today to discuss training options and products further.