Independent Introducing Brokers are required to submit an annual certified audit to the National Futures association. The due date depends upon the IIBs year end. For example, if their fiscal year end is December 31 audits must be submitted no later than March 31. However, if the 31st falls on a weekend, the audit must be submitted by the next business day. For example, March 31, 2018 falls on a Saturday. Therefore, the annual audit will be due by midnight on April 2, 2018.
On an annual basis Introducing Brokers should review all compliance and procedures. Additionally, it should be documented that such review and update has occurred.
Here is an example:
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
_____ Written Operational Procedures (incorporated in the written documents)
_____ Net capital computation – monthly
____ FCM AML Acknowledgements – annually
____ Cybersecurity Policy (ISSP) reviewed – annually
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