At the end of February, the NFA advised of an upcoming Notice to Members titled “NFA Compliance Rules 2-9 and 2-36: Members’ Use of Third-Party Service Providers” that will set out NFA expectations when outsourcing regulatory requirements to third parties.
In particular, the Interpretive Notice will provide guidance on the following areas: (i) initial risk assessment; (ii) onboarding due diligence; (iii) ongoing monitoring; (iv) termination; and (v) recordkeeping.
If you are utilizing third-parties to undertake functions that would otherwise be the responsibility of the Member firm, please review your outsourcing policy to ensure the NFA’s guidance is incorporated.
Click here to find out more.
Click for more on our NFA Compliance services.
