CFTC and NFA Enforcement Priorities 2020 Dec 05, 2019 For 2019 Turnkey staff noted an increased level of activity by the National Futures Association (“NFA”) with respect to audits conducted of member firms. NFA appeared to be more ambitious this calendar year with commodity trading advisors (“CTAs”), completing more scoped performance audits. The self-regulatory organization also seemed to also be more aggressively focused on Cybersecurity (“ISSP”) compliance. NFA continued its trend of requiring documentation in writing for virtually all compliance obligations. This approach has been consistent and steady over the last several years. Turnkey’s institutional clients also saw an increase in requests made directly from the CFTC for market information than in the previous twelve years of our business history. For 2020 we expect both the CFTC and NFA to continue the trends above.
NFA Audit Examination Deficiency Areas – March 2019 Mar 05, 2019 For 2019 the following areas seem to be where NFA is looking for deficiencies. Focus areas range from a firm’s information systems security program (“ISSP”) or cybersecurity policy, to more traditional trouble spots like accounting or promotional material best practices. The following is a brief summary of the most common deficiency and focus areas Turnkey has been seeing through the first quarter of 2019.
CFTC/NFA – Regulatory Recap – December 2018 Dec 12, 2018 It can be difficult to keep track the various regulatory announcements and changes that occur during a month. … Read More