A Commodity Trading Advisor is required to meet all compliance regulations on an annual basis along with quarterly reporting.

Below is an example of a compliance checklist that should be reviewed and documented on an annual basis:

_____    Check on line NFA registration records to make sure they are current

_____    NFA Annual Questionnaire – completed

_____   Signed Management Attestation and Self-Exam Checklist used on file – annually

_____    Ethics Training for new APs – within 6 months

_____   Ethics Review for all APs – every 3 years

_____   Promotional Material Folder or log updated with applicable support

_____   Complaint Folder or log updated with applicable support

_____   Branch Office Procedures reviewed (if applicable)

_____   Branch Office Examinations – at least one per year (if applicable)

_____   Disaster Recovery Procedures reviewed

_____   Privacy Policy reviewed

_____   Privacy Policy distributed to clients within last 12 months

_____   Written Operational Procedures (incorporated in the written documents) reviewed and agree with actual operations and Disclosure Document

_____   Cybersecurity policy (ISSP) reviewed/updated – annually

_____   Bunched order allocation procedures reviewed quarterly (if applicable)

_____   Quarterly financial reporting through NFA Easy File (PR)

____   Bylaw 1101 compliance records

____   General Partner financial records reviewed for appropriate disbursements

____   Sales emails periodic review for appropriateness and compliance with regulations.

_____   Updated disclosure document approved by NFA every 12 months if actively soliciting accounts

_____   Supporting documentation assessable for performance calculations

Completed by:                                                         

Date completed:                                                      

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