NFA Reminds Firms of Regulatory Obligations Based on Common Exam Deficiencies
In a series of Notices, NFA reminded member firms, by type, of their regulatory obligations based on common examination deficiencies.
NFA highlighted the following regulatory obligations, among others:
-
for swap dealers: business conduct standards, market practices, portfolio reconciliation and swap data reporting in NFA Notice I-21-06;
-
for futures commission merchants, forex dealer members and introducing brokers: supervision, the self-examination questionnaire and anti-money laundering in NFA Notice I-21-07;
-
for futures commission merchants only: notifications and public disclosures in NFA Notice I-21-07; and
-
for commodity pool operators and commodity trading advisors: self-examination questionnaires, pool financial reporting notification requirements and the calculation of financial ratios in NFA Notice I-21-08.
A common deficiency across all member types was the failure to properly train employees on cybersecurity. NFA reminded members that, pursuant to NFA Notice 9070, each member must adopt a written information systems security program to respond to unauthorized attacks and notify NFA, should such incidents occur, through the Cyber Notice Filing System.