NFA Notifies Members of Effective Date for New Requirements on Member Questionnaires

The NFA notified its members that the new requirements on Member Questionnaires will become effective on October 15, 2024.

As previously covered, the NFA Board adopted:

• Compliance Rule 2-52 ("NFA Member Questionnaire Requirements") which requires Member firms to submit the Member Questionnaire at least annually and more frequently in certain specified circumstances; it also sets forth specific requirements regarding who at the firm must review, sign and submit the Member Questionnaire (i.e. a principal of the swap dealer, and for other members "by an individual who is an associated person and principal of the Member (Qualified Individual)";
• a related Interpretive Notice, to provide more specific compliance guidance as to what constitutes a "material change" to business operations that would trigger the requirement to update the Questionnaire, and
• certain clarifying amendments to NFA Bylaw 301(h) ("Suspension and Termination of Membership and Associate Membership").