Nov 19, 2020 | News

Introducing Broker Checklist – Make Sure Your Compliance House is in Order

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.

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 annually

_____   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 by an Independent 3rd party

_____   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