Your NFA examination clock started ticking the day you registered.
You already know the situation. One random Tuesday, that examination notice hits your inbox. Suddenly, you’re digging through trade records, hunting for that cybersecurity policy you meant to formalize, and wondering if your AML procedures will pass scrutiny.
Every fund manager faces the same moment of truth: discovering what they should have fixed months ago. Performance calculations that seemed bulletproof now look questionable. Marketing materials reveal inconsistent disclaimers. Your disaster recovery plan exists primarily in your head.
Our mock audit service at Michael Coglianese CPA, P.C. stops that spiral before it starts. We run the full NFA examination playbook — examining documents, testing procedures, questioning staff — precisely how real examiners do it.
And you get the complete deficiency list while you can still do something about it.
Why a Mock NFA Audit Pays Off (Real Risks, Real Dollars)
You’ve probably seen firsthand what happens to firms that wing it and wait to fix mistakes until the last minute without proper prep. The NFA runs risk-based examinations, sometimes without warning, and loves finding the obvious stuff: promotional materials promising things you shouldn’t promise, PQR forms collecting dust past deadline at $200 per day in fines, registration lapses nobody noticed until an examiner asked.
We’ve watched the most competent managers write five-figure checks for violations a mock audit would have caught over coffee. The kind of violations that make you kick yourself: outdated disclosures, missing cybersecurity documentation, staff who can’t explain your own procedures.
Our mock audit hits everything real examiners check. We verify registrations, dissect your marketing materials, and test whether your written procedures match reality. You discover what’s broken while you can still fix it cheaply, privately, without regulatory footnotes following your firm forever.
What Our Mock NFA Audit Includes (Modeled on NFA’s Playbook)
You can discover what’s broken while you can still fix it cheaply, but only if we test everything examiners will. Our mock audit runs their exact playbook, so when the real exam hits, you’re watching little more than a rerun.
- Pre-Exam Prep Like They Do It: We start with an RFS-style request list, pre-exam questionnaire, and operations call. You’ll practice gathering documents and answering initial questions before pressure makes everyone forget where files live.
- Virtual Meets On-Site Testing: Examiners now run hybrid exams — Teams interviews plus targeted desk visits. We do the same. Remote walkthroughs for most items, then we show up to test the controls and records that matter most.
- The Rules They Love to Check: Supervision under Rule 2-9 (especially remote work oversight), books and records, including all those WhatsApp messages nobody captures, promotional materials with every disclosure they expect, cybersecurity documentation you swear exists somewhere, and those quarterly PQR and PR forms with supporting calculations.
- Critical Deadlines You Can’t Miss: Rule 2-50 notice events hit hard because margin calls and major redemptions need reporting by 5 p.m. CT the next business day. We test your readiness for these fire drills.
- Exit Interview Practice: We preview findings exactly how examiners deliver them, so you know which explanations work and which ones don’t.
What You Get: Deliverables That De-Risk Exam Day
First, you receive a color-coded findings map: red means fix immediately, yellow means address soon, green means you’re good. Each item shows the exact rule violated, who owns the fix, and when it needs completion.
We then update your Written Supervisory Procedures with easy-to-use templates: AP supervision checklists, marketing pre-clearance forms, and communication capture attestations. Your regulatory filing workpapers get organized too, with PQR and PR tie-outs, Rule 2-50 trigger matrices, and Rule 2-52 Member Questionnaire calendars.
Plus, you get the exam-day playbook. Who greets examiners, where every document lives, and how to handle exit interviews. When NFA asks for corrective action plans, you’ll already have answers ready.
How We Target the ‘Gotchas’ (So You Don’t Get Cited)
We know precisely what trips firms up every single time.
Start with promotional materials — the easiest place to rack up violations. One unlabeled hypothetical return, one missing risk disclosure, one performance claim without backup, and you’re writing remediation plans. We scrub every marketing piece, every pitch deck, every website page for the language that gets you cited.
Then there’s the stuff nobody remembers until exam day: your ISSP annual review that expired three months ago, cyber training certificates nobody saved, and AML refreshers your team swears they completed. We build tracking calendars and capture proof before these oversights become findings.
Financial reporting trips up even careful firms too, so we nip that in the bud. CPO and CTA ratios need accrual-based calculations with rock-solid documentation. Member and Self-Exam Questionnaires need proper signatures and retention. We verify the math, the backup, the deadlines, and then some.
Finally, we know that communications capture gets everyone. And because NFA counts every platform where business happens, from email to Slack to WhatsApp and even SMS texts, we test whether you’re actually capturing it all.
90-Day ‘Exam-Ready’ Timeline (On-Site or Virtual)
Three months from now, you’ll know exactly where you stand. Our mock audit unfolds in phases that mirror how real exams work, fixing problems as we find them.
- Days 1-15: We kick off with the dreaded request list. Except this time you’re not sweating deadlines. While you’re gathering documents, we tackle the low-hanging fruit that gets everyone. That hypothetical performance chart on your website? Needs a label. Those marketing emails your salesperson sends? Need approval documentation. Minor fixes now save major problems later.
- Days 16-45: Now we dig into what really matters. We test whether your supervision actually supervises, whether your cyber policy exists beyond good intentions, and whether those quarterly filings tie out to source documents. Your Self-Exam Questionnaire finally gets done right. Every gap we find becomes a fix-it list, not a deficiency letter.
- Days 46-75: Time to close every gap we found. Your Written Supervisory Procedures transform from wishful thinking into working documents. Those PQR calculations get bulletproof backup. You’ll have a Rule 2-50 matrix that actually tells you when to file notices. Real procedures, real evidence, real protection.
- Days 76-90: We run the whole exam experience. Your team practices pulling documents under pressure, answering examiner questions without rambling, and handling the exit meeting like pros. Management sees everything, signs off, and knows exactly what’s coming.
Make Your Next NFA Exam a Nonevent
NFA exams follow a predictable structure, but they’re unforgiving when it comes to the details. The firms that sail through have one thing in common: they’ve already been through the wringer with a mock audit. They’ve fixed the promotional material issues, captured the missing communications, and updated the stale questionnaires. When real examiners arrive, these firms pull documents confidently, answer questions calmly, and treat the whole process like the routine verification it should be.
Michael Coglianese CPA, P.C. runs these mock audits because our team includes former NFA compliance auditors and Big 4 accountants who’ve sat on both sides of the exam table. We know which citations hurt most, which procedures examiners scrutinize first, and which explanations satisfy them. Beyond mock audits, we handle everything NFA touches: compliance, registration, certified audits, tax prep, FR reports, and track records. We review your procedures before exam day, stand beside you during fieldwork, and help craft responses that resolve findings fast.
Ready to turn your next NFA exam into a nonevent? Contact Michael Coglianese CPA, P.C., to schedule your mock audit and get a customized timeline that fits you.