The National Futures Association (“NFA”) requires all its member firms, on an annual basis, to review their operations using NFA’s Self-Examination Questionnaire. The document is designed to aid members in recognizing potential problem areas and to alert them to procedures that need to be revised or strengthened. The latest questionnaire dated June 2020 can be found by clicking here. The same document serves all members although there are separate sections addressing the unique needs of FCMs, FDMs, IBs, CPOs, and CTAs.
To verify review of the self-examination questionnaire, members are required to transcribe on to company letterhead and sign the attestation found on page 5 of the questionnaire. Copies of the questionnaire and the signed attestation should be kept in your Compliance Binder for at least five years. Increasingly, the NFA is asking for a copy of these items as part of their routine audit process.
The NFA performs frequent audits of member firms. Failure to adhere to the NFA’s compliance requirements, including the Self-Examination Questionnaire provisions mentioned above, may subject the firm to disciplinary action. For more information or assistance in meeting your NFA compliance obligations, please contact Mike Coglianese at (630) 461-5841 or mike@cogcpa.com.