IB

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.