CFTC registration & NFA membership

The National Futures Association (NFA) is the industrywide, self-regulatory organisation for the U.S. derivatives industry, ensuring Members meet their regulatory responsibilities. The Commodity Exchange Act requires the following firm categories to hold a NFA membership:

• Commodity Pool Operators,
• Commodity Trading Advisors,
• Futures Commission Merchants
• Introducing Brokers

As the Commodity Futures Trading Commission (CFTC) has delegated registration responsibility to NFA, submission of an NFA membership application fulfils CFTC registration requirements.

Helping you successfully register with NFA

To ensure your application progresses smoothly and successfully, our experts will provide support to:

• Ensure you have a full understand of the regulatory obligations applicable to your category and the application requirements prior to proceeding
• Draft the application pack and compile supporting documentation
• Review and editing relevant compliance procedures as required
• Help you to deal with NFA queries and provide detailed advice and guidance at every stage

Guiding you through the registration process

Our team provide a tailored support service with a dedicated relationship manager to guide you every step of the way. Combining expert in-country expertise alongside access to global subject matter expertise, we look beyond the rulebook with a deep understand of what NFA are looking for throughout the process

While the registration process can differ depending on your category and business activities, the registration process can typically take between 1-2 months to prepare materials and a minimum of 2 months for NFA to review and approve.

Key stages

• 1. Scoping and preparation

  After assessing the scope and agreeing the timetable of activities, we’ll determine the individuals and entities that will be required to be listed as principals and associated persons while assessing proficiency requirements.

  We’ll also prepare and distribute questionnaires to obtain personnel and firm data needed to complete any applicable forms while reviewing any potential risk areas that could impact the application process.

• 2. Preparing application materials

  We’ll prepare the application pack for submission, including relevant compliance procedures, financial statements, reports and any category specific requirements. We’ll also prepare the correct access to NFA’s systems to submit.

• 3. Application submission

  We’ll complete and submit relevant filings, including:

  • Submission of NFA membership application
  • Form 7-R
  • Form 8-R
  • Financial filings where applicable
• 4. Satisfying compliance requirements

  Any requested compliance procedures will need an initial review by NFA. We’ll collate and submit all the required supporting materials and work with you to address any gaps or areas of concern.

• 5. Further information requests and ongoing application monitoring

  To ensure the application process doesn’t stall unnecessarily, we’ll frequently check in with nominated individuals as they complete testing and background check enquiries, monitor any incoming application and membership fee requirements and assist with preparing responses to requests for further information.

• 6. Preparing Annual Questionnaire responses

  We’ll prepare an easy-to-use template and review your responses ahead of submission, ensuring they cover the areas and level of detail NFA expects

• 7. Final decision and approval

  The NFA will advise when you have met their conditions and if the firm has been granted approval. If membership is denied, you’ll have the right to appeal and, in some cases, to have a hearing before the Membership Committee to demonstrate membership requirements had been met.

Start your journey

Get in touch using the form below and a member of the team will get back you as soon as possible.