Oct 31, 2017 | News

Futures Commission Merchants – Audit Due Date and Compliance Checklist

Futures Commission Merchants are required to submit an annual certified audit performed by an independent accountant to the NFA.  The annual audit is due 60 days after the FCMs fiscal year end.  For example, if year end is December 31, 2017 the certified audit must be submitted to NFA no later than March 1, 2018.

FCMs should review their compliance checklist on an annual basis and documented that such review has occurred.  An example of an annual checklist is below.  However, FCMs are required to meet specific regulatory obligations.  For a more detailed list of annual requirements, please refer to NFA website here.

_____    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

_____   AML Training for all APs – annually

_____   Promotional Material Folder or log

_____   Complaint Folder or log

_____   Suspicious Activity Log

_____   OFAC Log of all customers

_____   Branch Office Procedures reviewed

_____   Branch Office Examinations – annually

_____   AML Procedures reviewed – annually

_____   Annual AML Review completed – within 12 months

_____   Disaster Recovery Procedures reviewed – annually

_____   Privacy Policy reviewed

_____   Privacy Policy distributed to clients within last 12 months

_____   Written Operational Procedures (incorporated in the written documents)

_____   Net capital computation – monthly

____     FCM AML Acknowledgements – annually

____     Cybersecurity Policy (ISSP) reviewed – annually

Completed by:                                                         

Date completed: