Dec 16, 2019 As 2019 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 generally been more active with audits than they have in previous years. Earlier this month Turnkey published an article about enforcement actions, patterns, and trends to look out for in 2020. 2019 NFA Annual Obligations Update/Review Compliance Manual as applicable Consider sending annual BASIC notice to customers Annual privacy notice to customers (consider changes to policy) For IB’s update and obtain New FCM AML reliance agreements. Complete NFA’s Annual Questionnaire Pay NFA Dues and update all registration information Complete NFA’s Self-Examination Questionnaire for main office and branch offices Ensure branch and GIB locations have been audited within the calendar year (call Turnkey for help!) Conduct all trainings necessary such as Anti-Money Laundering (“AML”), Ethics, Cybersecurity, Identity Theft training for relevant employee Test your Cyber Security and Disaster Recovery Plan and make any necessary adjustments. 2019 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 some articles we have written in 2019 on new regulatory obligations that you may want to reconsider: NFA Required Fund Manager Internal Control Policies ISSP Changes Required NFA Audit Examination Deficiency Areas IB and FCM Supervision Branch and GIB Offices CTA and CPO Performance Accounting Changes NFA Promotional Material Guidelines 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 2020 is your best year of compliance yet!