The NFA requires member FCMs, RFEDs, IBs, CPOs, and CTAs must review their operations on an annual basis using the NFA’s Self Exam Questionnaire.

As of June 2020, the NFA has updated the questionnaire to reflect recent rule amendments that became effective over the past year.

These amendments include:

• Updated Interpretive Notice regarding Due Diligence reviews, written supervisory procedures, and ongoing training. Details here.
• Updated Interpretive Notice regarding communications with the public and promotional material.  Details here.
• Updated Interpretive Notice regarding bunched orders for multiple accounts. Details here.

Additionally, if you are a Commodity Trading Advisor or Commodity Pool Operator, please re-affirm all exemptions within 60 days of calendar year end.  The NFA will send a reminder during the affirmation period.

If you are in need of a compliance check up and/or updated procedures, please call Mike Coglianese at 630-461-5841 or email mike@cogcpa.com.