Evolving Regulatory Landscape The CFTC and NFA regulatory landscape is always evolving. A growing number of registrants are now “working from home”. Working from home means not maintaining a traditional centralized office location or technology infrastructure. If you’re working remote or allowing staff to, have you truly considered the impact of this decision on your overall compliance program? Remote Work Compliance Obligations FCM, IB, CPO, and CTA registrants are required to supervise all commodity-interest related electronic communications employees have. In order for this to occur those communications must first be captured and retained. At a minimum all registered firms must reliably capture both company and personal: E-mails Instant Online Chat Messages Mobile Text Messages Social Media Messages Certain Oral Communications How is your firm ensuring that customer communications are being properly retained with staff working at home? Are you capturing communications on employee personal devices? Are all staff using centralized communication systems operated by your firm? Have you evaluated the vendors being utilized by remote workers against your firm’s third party service provider policies? If you answered no to any of these questions or are unsure you might want to consider reaching out to Turnkey. Centralized Record Retention Systems CFTC and NFA registered firms must retain most broker communications for five (5) years. Are you doing this? Can you do this? Turnkey has partnered with a leading technology firm to help you put in place the systems necessary to allow staff to work from home full time while maintaining record retention compliance. Turnkey’s solution will help your firm to: Properly implement uniform E-mail hosting and synchronization Record phone lines and manage recordings Capture mobile text messages Ensure chat communications are retained and backed up Properly manage IT Infrastructure Proper Communication Supervision After electronic communication records have been captured, those records then must also be monitored. A modern brokerage or trading business may capture hundreds, if not thousands, of messages a day. Do you have a plan for staying on top of this level of communication? Turnkey can help registered firms to properly supervise broker and trader communications across all mediums. Our offering can help you to meet your obligations under company cybersecurity, disaster recovery, and third-party service provider policies. If you have not considered your electronic record retention policies or if you have no plan in place to review communications please submit our online request form to learn more today.