Annual IB Requirements
Below is a listing of certain annual requirements for introducing brokers (IB). This list serves as a reminder of certain yearly requirements and does not reflect all IB responsibilities.
Cybersecurity
- Review the IB's written information systems security program (ISSP) using either in-house staff with appropriate knowledge or by engaging an independent third-party information security specialist.
- Provide training to employees upon hiring, at least annually thereafter, and more frequently if circumstances warrant.
Dues
- Pay NFA dues (including a $100 registration records maintenance fee for each category of registration) on the IB's registration anniversary date.
Questionnaires and Updates
- Complete NFA's Member Questionnaire on the IB's membership anniversary date using NFA's Member Questionnaire system.
- Complete the electronic Annual Registration Update in NFA's Online Registration System (ORS) when notified through NFA's Dashboard.
- Complete NFA's Self-Examination Questionnaire.
Reports and Exemptions
- Send the IB's Privacy Policy to current participants. See Appendix D of the Self-Examination Questionnaire for details.
- Submit financial reports to NFA using NFA's EasyFile System (or WinjammerTM for Broker/Dealers)
- The FCM that carries your customer accounts will be contacting your customers annually at a minimum to verify that the information obtained under NFA Compliance Rule 2-30(c) remains materially accurate, and provide the customer with an opportunity to correct and complete the information. If the FCM notifies you of any material changes to the information, assess whether an additional risk disclosure is required to be provided to the customer.
Supervision
- Supervise the operations of any Branch Offices and conduct an annual onsite inspection of every Branch Office.
Testing and Training
- Test the disaster recovery plan and make necessary adjustments.
- Provide ethics training as outlined in the IB's written ethics training procedures.
- Conduct anti-money laundering (AML) training for relevant employees and complete an audit of AML procedures and training.