Summer is a good time to review your annual NFA requirements to make sure you remain in compliance with the National Futures Association.

Here are just a few reminders:

• Cybersecurity – Each member must formalize and implement a written Information Systems Security Program (ISSP). This program must be reviewed and updated on an ongoing basis including training for all new hires.  A detailed interpretive notice as well as frequently asked questions are available on NFA’s website.  To review the interpretive notice, click here.
• Pay your annual NFA Dues (currently $750) on your anniversary date.  Failure to do so results in a late charge of $25 per month.  The NFA will assume NFA Membership withdrawal for failure to pay after 30 days.
• Update the Annual Questionnaire by your anniversary date as well as the Registration Update and Self-Examination Questionnaire.
• Supervisory Procedures–conduct and review an annual onsite inspection of all Branch Offices.  Make sure all APs are following proper procedures.
• Testing and Training of the following:
  • Disaster Recovery Plan
  • Ethics Training (following your Written Ethics Training Procedures)
  • Annual AML training for employees and complete an audit of AML procedures and training.  To review the minimum requirements, click here.

If you need assistance updating procedures or need your annual AML audit performed by an independent service provider, please call Mike Coglianese at 630-461-5841 or email Mike@cogcpa.com.