CFTC, NFA, CME – Written Supervisory Procedures Oct 29, 2020 Commodity Futures Trading Commission (“CFTC”) registrants often mistakenly believe company written supervisory procedures (“WSPs”) once established do not need to be adjusted. Many times, after Turnkey Trading Partners (“Turnkey”) establishes a consulting relationship with a new customer, it is quickly determined that an overhaul of company policies and procedures is necessary. How can this be? Where is the disconnect between industry participants and regulators occurring? Can this problem be avoided?
Relief from the On-Site Annual Inspection of Branch Offices and Guaranteed IBs Oct 05, 2020 Due to COVID-19, NFA understands that it may difficult for Members to conduct on-site inspections at branch offices and guaranteed IBs this year. Therefore, although Members must conduct the required annual inspection of each branch office and guaranteed IB by December 31, 2020, firms may conduct these inspections remotely.
CTA-PR, CPO-PQR Accounting and Performance Reporting Sep 30, 2020 Recently, Turnkey has noticed that during NFA audits, examiners are starting to ask more about CTA and CPO accounting methodology. In other words, they want to understand book keeping process and record keeping habits. NFA auditors are also regularly asking firms about accrual-based accounting versus cash-based accounting.