Teacher and consultant to the futures industry since 1983

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From the Founder
Anti-Money Laundering
Forex Information

Excellence Award
Tips for healthy trading
FAQs (email)
Articles
Series Three Info
CTA and CPO info

NFA style Field Audits
IB & Branch setup
Consulting
Career Placement

Privacy Policy

Futures Site Web Excellence
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Items you need to improve and protect your FCM or IB...

1.   Very important and useful forms and letters for different applications for the FCM and the Introducing Broker.  Visit our "forms" page.

WHAT THE IB SHOULD HAVE READY
WHEN THE AUDITORS COME TO CALL


As a Guaranteed Introducing Broker, you will have a good start on a smooth and cooperative audit if you will have the following information ready for the auditors.   Nobody likes to go through an audit, and when it is performed by the regulatory body of the industry you work for, it can be very intimidating to say the least.  You should understand that an uncooperative or adversarial stance in these situations accomplishes nothing.

The regulators, ok.. let's say it.. the NFA, performs a very important function.  Those of you who were around before the NFA forced the Series 3 exam on all of us will certainly remember the reputation that futures representatives had.   Much of that reputation was of course deserved since any and all persons could be "sales reps" in this business.  My own opinion is that the institution of the Series 3 did begin to clean up our industry.  In fact, With the "self regulation" in futures, I believe we have for the most part offered an opportunity to more people to invest, and for more people to have genuine careers in this business.

So when your turn comes, just have the following things ready, and be as cooperative as you can.  You may be supprised to find that under the gruff exterior of the auditor there lies a pussycat?

Good luck with your audit, and may you be successful in your business and with your customers.

1. CLEARING AGREEMENT WITH FCM
2. COPY OF lFR PART B AGREEMENT (Guarantee agreement)
3. LETTER FROM FCM AUTHORIZING BANK DEPOSITS/ACCEPTANCE OF CUSTOMER FUNDS
4. LATEST NFA REGISTRATION INFORMATION - copy of 7R
5. PREVIOUS NFA AUDITS (if applicable)
6. PREVIOUS FCM REVIEWS - fax or on-site (if applicable)
7. ALL NFA SELF EXAMINATION QUESTIONNAIRES
8. ETHICS TRAINING CLASS CERTIFICATIONS AND PROCEDURES
9. CUSTOMER EQUITY RUNS (most current complete month and copy of run from current week)
10. ORDER TICKETS
11. CUSTOMER ACCOUNT
12. AP and PRINCIPAL'S 8-Rs
13. COPIES OF CUSTOMER CHECKS - BANK DEPOSITS (if not in customer files)
14. DISCRETIONARY ACCOUNTS (POA) - (tickets, account forms, monthly statements)
15 NUMBER OF, AND NAMES OF, APs HAVING POA
16. TOTAL NUMBER OF ACCOUNTS OF EACH OF THESE APs
17. NUMBER OF ACCOUNTS THAT EACH OF THESE APs HAVE POA OVER
18. FCM COMPLIANCE MANUAL
19. CUSTOMER COMPLAINT FILE
20. ADVERTISING/SALES PROMOTION FILE
21. BRANCH OFFICE EXAMINATION FILE (if applicable)
22. BANKING RECORDS OF THE IB

23. PRIVACY POLICY
24. BUSINESS CONTINUITY PLAN (DISASTER RECOVERY PLAN)
25. ANTI-MONEY LAUNDERING PROCEDURES
26. Privacy Policy
27. Anti-Money Laundering Procedures.


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Last modified: April 05, 2008