Expiration of Temporary Relief from Fingerprinting Requirements

On September 29, 2020, DSIO issued an email alert stating that this no-action relief would not be extended beyond September 30, 2020. Therefore, beginning on October 1, 2020, all applicants for AP registration and all-natural persons being listed as a principal of an applicant or registrant must submit the applicant’s or natural person principal’s fingerprints on an applicant fingerprint card, which are available at facilities offering fingerprinting services.

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.

CTA-PR, CPO-PQR Accounting and Performance Reporting

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.