Effective Date Set for NFA Supervisory Framework on Outsourcing Arrangements

NFA set the effective date of September 30, 2021, for a recently adopted interpretive notice concerning members' use of third-party service providers.

As previously covered, the NFA stated firms should tailor written supervisory frameworks to their specific business activities, identifying the following specific areas to be addressed: (i) initial risk assessment, (ii) onboarding due diligence, (iii) ongoing monitoring, (iv) termination and (v) recordkeeping.