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.
Expiration of Temporary No-Action Relief from the Requirement to Submit a Fingerprint Card with Form 8-R Sep 30, 2020 Given the widespread, if restricted, reopening of businesses and services in most parts of the country, and the availability of law enforcement offices to persons needing to have fingerprints taken, DSIO now believes that the blanket relief provided under Staff Letters 20-16 and 20-20 is no longer urgently needed. Accordingly, that general relief will be permitted to expire September 30.
NFA Virtual Audits – A Follow-up Aug 28, 2020 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.