Futures Commission Merchants are required to submit an annual certified audit performed by an independent accountant to the NFA. The annual audit is due 60 days after the FCMs fiscal year end. For example, if year end is December 31, 2017 the certified audit must be submitted to NFA no later than March 1, 2018.
FCMs should review their compliance checklist on an annual basis and documented that such review has occurred. An example of an annual checklist is below. However, FCMs are required to meet specific regulatory obligations. For a more detailed list of annual requirements, please refer to NFA website here.
_____ Check on line NFA registration records to make sure they are current
_____ NFA Annual Questionnaire – completed
_____ Signed Management Attestation and Self-Exam Checklist used on file – annually
_____ Ethics Training for new APs – within 6 months
_____ Ethics Review for all APs – every 3 years
_____ AML Training for all APs – annually
_____ Promotional Material Folder or log
_____ Complaint Folder or log
_____ Suspicious Activity Log
_____ OFAC Log of all customers
_____ Branch Office Procedures reviewed
_____ Branch Office Examinations – annually
_____ AML Procedures reviewed – annually
_____ Annual AML Review completed – within 12 months
_____ Disaster Recovery Procedures reviewed – annually
_____ Privacy Policy reviewed
_____ Privacy Policy distributed to clients within last 12 months
_____ Written Operational Procedures (incorporated in the written documents)
_____ Net capital computation – monthly
____ FCM AML Acknowledgements – annually
____ Cybersecurity Policy (ISSP) reviewed – annually
Completed by:
Date completed: