NFA Self-Examination Questionnaire: For FCMs, FDMs, IBs, CPOs and CTAs
The NFA issued a revised version of its self-examination questionnaires for FCMs, FDMs, IBs, CPOs and CTAs. NFA member firms are required to complete relevant sections of these questionnaires on an annual basis. The revised version of the Questionnaire incorporates revisions to the CPO Supplemental Questionnaire to update Form PQR reporting requirements to reflect recent amendments to NFA Compliance Rule 2-46 (see p. 35 of the Questionnaire). For further guidance on the revised Form PQR reporting requirements, see the Cadwalader News article, attached here. For ease of reference, we set out below the topics covered in the various self-examination questionnaires:
|
Introduction |
3 |
|
Sample Attestation |
4 |
|
General Self-Examination Questionnaire for All Members |
5 |
|
Registration |
5 |
|
Supervision |
6 |
|
Ethics Training |
8 |
|
Business Continuity and Disaster Recovery |
8 |
|
Account Opening |
8 |
|
Privacy Rules |
9 |
|
Promotional Material |
9 |
|
E-Mails |
11 |
|
Websites and Social Networking Groups |
11 |
|
Supplemental Questionnaire for FCMs |
13 |
|
Financial |
13 |
|
Supervision |
14 |
|
Due Diligence Prior to Trading |
15 |
|
Anti-Money Laundering |
15 |
|
Customer Trading |
16 |
|
Margins |
18 |
|
Account Statements |
18 |
|
Give-up Transactions |
18 |
|
Automatic Order Routing System |
18 |
|
Security Futures Products |
19 |
|
Supplemental Questionnaire for FDMs |
22 |
|
Financial |
22 |
|
Disclosure |
23 |
|
Supervision |
23 |
|
Customer Trading and Reporting |
24 |
|
Security Deposits |
24 |
|
Electronic Trading Systems |
25 |
|
Supplemental Questionnaire for IBs |
27 |
|
Supervision of Accounts |
27 |
|
Due Diligence Prior to Trading |
27 |
|
Anti-Money Laundering Program |
28 |
|
Cash Flow |
28 |
|
Customer Trading |
28 |
|
Financial (Independent IBs only) |
29 |
|
Automatic Order Routing System |
30 |
|
Security Futures Products |
31 |
|
Supplemental Questionnaire for CPOs |
34 |
|
Account Statements |
3 |
|
Financial |
34 |
|
Disclosure Document |
36 |
|
Security Futures Products |
36 |
|
Supplemental Questionnaire for CTAs |
37 |
|
Disclosure Document |
37 |
|
Bunched Orders |
37 |
|
Post-Execution Allocation of Bunched Orders |
37 |
|
Security Futures Products |
38 |
|
Sources of Additional Information |
39 |
View Questionnaire here (links externally to NFA website).As to the privacy questionnaire, firms should also be mindful of the fact that the CFTC and the SEC have recently jointly adopted rules on information security.See: Identity Theft Red Flags Rules (Joint Final Rules; Fed. Reg. Version) (with Lofchie Comments).