NFA Virtual Audits – A Follow-up

Last month, Turnkey discussed the need for firms to begin maintaining all required documents digitally as well as some recent changes to the NFA audit process. As mentioned, due to the pandemic, NFA has not been traveling since March of 2020 and has been conducting all reviews virtually. Turnkey has assisted on many of these virtual reviews and feels it is prudent to share some key additional takeaways.

CFTC and NFA Compliance: Covid’s “New Audit Normal”

Previously NFA member firms had their annual reviews conducted on-site and in-person, Covid-19 has changed all of that.  For the foreseeable future all outside office reviews, including those of FCMs, IBs, GIBs, CTAs, and CPOs will be conducted remotely via a virtual meeting of some type.

New NFA Self-Exam; Subtle Changes… BIG Implications

Periodically, NFA updates the Self-Exam Questionnaire, which most recently occurred June 2, 2020.  When these updates are made NFA has the expectation that firms will use the most current version of the Questionnaire.