Relief from the On-Site Annual Inspection of Branch Offices and Guaranteed IBs

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.

Expiration of Temporary No-Action Relief from the Requirement to Submit a Fingerprint Card with Form 8-R

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

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.