Independent IB Reporting Requirements
Financial reports – audited
When
Annually 1-FR-IB due 90 days after fiscal year end; FOCUS due 60 days after fiscal year end
Annually 1-FR-IB due 90 days after fiscal year end; FOCUS due 60 days after fiscal year end
Financial reports – unaudited
When
Semi-annually for 1-FR-IB as of the middle and the close of each fiscal year, due within 17 business days of period end.
FOCUS due on same cycle as that required by FINRA and within 17 business days after the required date.
Semi-annually for 1-FR-IB as of the middle and the close of each fiscal year, due within 17 business days of period end.
FOCUS due on same cycle as that required by FINRA and within 17 business days after the required date.
Subordinated Loan Agreements (SLA) standard forms are available from NFA
When
If applicable
If applicable
Information Required
The loan and all changes and amendments must be approved by NFA before the effective date. If approved by DEA, please file approval letter with NFA.
The loan and all changes and amendments must be approved by NFA before the effective date. If approved by DEA, please file approval letter with NFA.
Member Questionnaire
When
Annually, to coincide with annual dues.
Members must update the Questionnaire throughout the year upon any changes to their business operations
Annually, to coincide with annual dues.
Members must update the Questionnaire throughout the year upon any changes to their business operations
Information Required
NFA sends an annual notice indicating how to access the questionnaire.
See NFA Compliance Rule 2-52.
NFA sends an annual notice indicating how to access the questionnaire.
See NFA Compliance Rule 2-52.
Notice of undercapitalization
When
If applicable
If applicable
Information Required
Immediate notification when capital falls below level set forth in NFA Financial Requirements.
Immediate notification when capital falls below level set forth in NFA Financial Requirements.
Non-current books and records
When
If applicable
If applicable
Information Required
Same day notification when required books and records are not current. A written report stating corrective action must follow within 48 hours.
Same day notification when required books and records are not current. A written report stating corrective action must follow within 48 hours.
Cybersecurity incident
When
If applicable
If applicable
Information Required
Prompt notification is required for certain cybersecurity incidents. See NFA Interpretive Notice 9070 for further information.
Prompt notification is required for certain cybersecurity incidents. See NFA Interpretive Notice 9070 for further information.
How
EasyFile
EasyFile
Net capital computations
When
Monthly
Completed withing 17 days of month end
Monthly
Completed withing 17 days of month end
Information Required
Monthly net capital computations must be maintained; however, they do not need to be sent to NFA unless they fall into one of the above categories.
Monthly net capital computations must be maintained; however, they do not need to be sent to NFA unless they fall into one of the above categories.
How
N/A
N/A
Material inadequacies noted by CPA in audited financials
When
If applicable
If applicable
Information Required
Notification of such material inadequacy within 24 hours. A written report stating corrective action must follow within 48 hours.
Notification of such material inadequacy within 24 hours. A written report stating corrective action must follow within 48 hours.
Request for extension of time to file financial reports
When
If applicable
If applicable
Information Required
If firm is also registered as a B/D, must file request and DEA response with NFA.
If firm is also registered as a B/D, must file request and DEA response with NFA.
Request to change fiscal year end
When
If applicable
If applicable
Information Required
If firm is also registered as a B/D, must file request and DEA response with NFA.
If firm is also registered as a B/D, must file request and DEA response with NFA.
The above information can be found in NFA Financial Requirements Section 5, NFA Interpretive Notice 9070, on NFA’s website, and in CFTC Regulations 1.10, 1.12, and 1.17.