NFA Notice 1-13-08: FCM Responsibilities for the Review and Approval of "Guaranteed Introducing Brokers" (GIB) Communications with the Public

The NFA has released a Notice to Members to remind Member FCMs of their supervisory responsibilities with respect to Guaranteed Introducing Brokers' ("GIBs") promotional material and communications with the public.

NFA Compliance Rule 2-9 ("Supervision") and the related Interpretive Notice ("Supervision of Branch Office and Guaranteed Introducing Brokers") outline an FCM's supervisory responsibilities with respect to the activities of its GIBs. The Interpretive Notice requires that NFA Members adopt written procedures regarding the use of promotional material and communications with the public. These procedures require that a Guarantor FCM review and approve all GIB promotional material prior to use. Therefore, in order to ensure that the Guarantor is adequately supervising its GIB's use of promotional material, all promotional material should be reviewed and approved by the Guarantor FCM prior to submitting the material to NFA.

See: NFA Notice I-13-08 ("FCM responsibilities for the review and approval of their Guaranteed Introducing Brokers' communications with the Public").