NFA Supervision Branch and GIB Offices

Starting in June, NFA will now require firms to put in place a due diligence review process for each branch office, guaranteed IB and their personnel. NFA has also stated that an effective oversight program of branch offices and guaranteed IBs also includes written supervisory policies and procedures describing a Member’s process for performing routine surveillance and supervision, as well as annual inspections that are documented through a written report.

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.