New NFA Promotional Material Guidelines

When National Futures Association (“NFA”) member firms advertise they open themselves up to a great deal of regulatory risk. Without proper consideration, even the most innocent and well-intended efforts to promote a business can land CFTC registered firms in hot water.  On August 29th, 2019 NFA announced proposed amendments to Compliance Rules 2-29 and 2-36. Within this announcement they also updated and harmonized several well-known Interpretive Notices.  NFA’s proposed changes have now been adopted and will go into effect as of January 1, 2020. All member firms are strongly encouraged to read the entirety of NFAs rule and interpretive notice adjustments. Turnkey would like to focus on a few key adjustments that we believe could significantly impact the industry.

NFA Audit Examination Deficiency Areas – March 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.