The National Futures Association published an updated version of its Self Examination Questionnaire for FCMs, FDMs, IBS, CPOs and CTAs to reflect recent regulatory changes, and for Forex Dealer Members, certain rule changes to enhance protections for retail customers that go into effect in January 2016. (Click here for an overview of these changes for FDMs in the article, "CFTC Approves NFA Enhanced Customer Protection Rules for FX Retail Clients; Commissioner Bowen Says More Protection Needed" in the August 30, 2015 edition of Bridging the Week.) Under NFA rules, members must review their operations on an annual basis using NFA’s most current questionnaire. Each questionnaire must be reviewed by an appropriate supervisory person, who must sign and date an attestation. A separate attestation is required for each branch office.
Compliance Weeds: The NFA Self-Examination Questionnaire is just one of the many useful guidances that US futures registrants can utilize to assess the completeness of their internal policies and procedures. Other publications published by regulators that registrants may find useful are: (1) NFA Regulatory Requirements for FCMS, IBs, CPOs and CTAs (click here to access); (2) Joint Audit Committee Margins Handbook (click here to access); and (3) Commodity Futures Trading Commission Form 1-FR-FCM Instructions (click here to access).