CFTC, NFA, CME – Written Supervisory Procedures Oct 29, 2020 Commodity Futures Trading Commission (“CFTC”) registrants often mistakenly believe company written supervisory procedures (“WSPs”) once established do not need to be adjusted. Many times, after Turnkey Trading Partners (“Turnkey”) establishes a consulting relationship with a new customer, it is quickly determined that an overhaul of company policies and procedures is necessary. How can this be? Where is the disconnect between industry participants and regulators occurring? Can this problem be avoided?
Relief from the On-Site Annual Inspection of Branch Offices and Guaranteed IBs Oct 05, 2020 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.
NFA Virtual Audits – A Follow-up Aug 28, 2020 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.