Based on feedback we are hearing from our clients who have undergone recent NFA Surprise Examinations, there are a few reminders and good practices to develop as NFA Members.
If you maintain written operational procedures, you must not only follow your procedures, but document the fact that they are reviewed checked as often as indicated in your procedures. For example, if you indicate in your procedures that you will maintain a transaction log, you must create one and prove that it has been updated in accordance with the timeframe spelled out in your procedures. We are hearing feedback that verbal affirmation of such practice is not enough and may be deemed as insufficient during an NFA Examination.
Therefore, we are recommending that as soon as you follow your procedures, whether it be Ethics Training, Risk Disclosure, testing your Disaster Recovery Plan, or reviewing promotional or complaint logs, you document and date the fact that it has been completed in written or electronic format.
If you would like us to perform a Mock NFA Audit, please contact Mike at mike@cogcpa.com or call him directly at 630-351-8942.