NFA Registration Update
Effective June 1, 2014, NFA imposed a $1,000.00 late disclosure filing fee for members who fail to disclose or updateregistration records involving prior and/or current disciplinary matters.
All disciplinary matters involving members and APs are considered properly disclosed if registrations are updated prior to NFA discovering them. Non-disclosure of disciplinary actions will result in the $1000.00 fine.
The NFA rule can be read here.
CPO Reminder – Financial Statements must comply with GAAP (Generally Accepted Accounting Principles)
NFA has recently been identifying and advising CPOs with regard to making sure their financial statements are in compliance with GAAP. As a reminder to all CPOs, organizational costs must be expensed as incurred rather than capitalized and amortized over a period of time. Feel free to give us a call if this requires further explanation.
FCM Updates and Reminders
FCMs must now make the following information available on its website:
Moreover, FCMs are required to be make public the Statement of Financial Condition, the Statement of Segregation Requirements and Funds in Segregation for Customers Trading on U.S. Exchanges, the Statement of Secured Amounts and Funds Held in Separate Accounts for 30.7 Customers Pursuant to Commission Regulation 30.7, the Statement of Cleared Swaps Customer Segregation Requirements and Funds in Cleared Swaps Customer Accounts Under Section 4d(f) of the Act, and all related footnotes to the above schedules that are part of the FCMs most current certified annual report pursuant to 1.16.
Introducing Broker Reminders
It is imperative for all Introducing Brokers to remain in compliance with current NFA regulations or face hefty fines. We recommend the following be reviewed on a continuous or annual basis:
Also, if IIBs fall below the Net Capital Requirement at any point in time, it is required that you file notice with NFA and file a 1FR within 24 hours. There may be fines assessed by NFA when an IIB falls below the minimum net capital requirement. It is required that Net Capital Computation records be maintained on a monthly basis. However, we recommend that IIBs be aware of the status of their Net Capital on a daily basis.
As a reminder, the semi-annual 1FR filing is due to NFA 17 business days after period end (June 30, 2014). We recommend all IIBs file their 1FRs prior to July 23, 2014. There is a $1,000.00 fine per day the filing is late.
If you have any questions or need assistance with updating and reviewing your procedures, please call Mike Coglianese at 630-351-8942 or email mike@cogcpa.com.
More compliance information can be found by visiting our website at www.cogcpa.com.