In January 2009, staff of the Division of Clearing and Intermediary Oversight (“Division”) notified NFA that the Division would be commencing a review of NFA’s Registration Program. Following document collection and review, Division staff conducted a three-day, on-site visit to NFA’s Chicago headquarters in April 2009.
During this on-site visit, Division staff interviewed the supervisory staff of NFA’s Membership and Registration Department (“Registration Department”) and tested NFA’s Online Registration System (“ORS”). Following the on-site visit, Division staff collected further information and conducted further testing, as necessary, to reach the findings and develop the action items presented herein.
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Findings, Recommendations and Action Items: Overall, the Division has found that NFA’s Registration Department has sufficient procedures to execute the Commission’s delegated registration and fitness functions with respect to the vast majority of registrants. However, the Division also identified certain key areas in which the Commission’s and/or NFA’s procedures must be improved.