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
_____ 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
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