In response to the ongoing Coronavirus pandemic, both the CFTC and NFA have released several notices relating to their response. These notices also indicate what CFTC registrants and NFA members should do to remain compliant in these unprecedented times.  While Turnkey recognizes navigating CFTC and NFA regulations may not be your first priority, making the following adjustments will be required to avoid future disciplinary action.

At the forefront of regulator concerns, firms must ensure their Business Continuity Disaster Recovery Plan (BCDR) and Information Systems Security Program (ISSP) are up to date. These documents must be modified to account for additional procedures needed during a pandemic. Additional measures the plan must consider also include: how firms will continue to operate effectively through pandemics, a refresh on training for how employees should operate while working remotely, and an assessment of related risks of all types including risks to key industry relationships. Firms may also want to include additional supervisory procedures for employees working from home.  It is important to also remember that all outside office locations have a localized BCDR and ISSP which considers location specific issues.

If your firm has not yet considered these policy adjustments or made arrangements related to these updates please contact us today at (312) 324-0040, via email, or by submitting an online support request at our website.  Turnkey has already been assisting many of our customers in dealing with the Coronavirus pandemic. Our team is standing by to do whatever we can to help your firm continue operations as usual.