Initial and Periodic Ethics Training

Exchange Analytics provides two Ethics Training Courses: Initial Ethic Training to be taken within six months of employee registration, and Periodic Ethics Training for ongoing education.

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CTC/NFA Ethics Training Requirement Background

The Commodity Futures Trading Commission’s Statement of Acceptable Practices mandates that each firm adopt and implement an appropriate ethics training plan. The NFA has issued an Interpretive Notice regarding Ethics Training providing further guidance to firms on how to meet ethics training requirements.

Appropriate employees of these NFA-member entities are required to take Initial and Periodic Ethics training:

  • Futures Commission Merchants (FCMs)
  • Independent and Guaranteed Introducing Brokers (IBs)
  • Commodity Trading Advisors (CTAs)
  • Commodity Pool Operators (CPOs)
  • Retail Foreign Exchange Dealers (RFEDs)
  • Swap Dealers (SDs)
  • Major Swap Participants (MSPs)

Ethics Training Course Benefits

  • Receive proof of compliance certificate
  • Fulfills regulatory ethics requirements
  • Updates staff on industry ethics standards
  • Written by a compliance & ethics expert

Initial Ethics Training Course

  • Course Type: Initial Ethics (for registrants who have never taken an ethics course)
  • Length of Course: Approximately 90 minutes; you may save your progress and return to the program as often as needed.
  • Price: $75 (corporate discount volume pricing available)
  • Frequency: Within 6 months of registration
  • Course Outline And Provider Qualifications: Download PDF
  • What's Included: Interactive course delivered via secure LMS platform; course completion confirmation to trainee and firm; electronic record archiving; on-demand record retrieval.

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Periodic Ethics Training Course

  • Course Type: Periodic Ethics [If your firm engages exclusively in institutional business, inquire about the institutional version of our Periodic Ethics Training.]
  • Length of Course: Approximately 40 minutes; you may save your progress and return to the program as often as needed.
  • Price: $35 (corporate discount volume pricing available)
  • Frequency: Varies by firm; typically at least every three years
  • Course Outline And Provider Qualifications: Download PDF
  • What's Included: Interactive course delivered via secure LMS platform; fulfillment confirmation to trainee and firm; electronic record archiving; on-demand record retrieval.

 

Take the Course Now Corporate pricing

Ethics Training Requirements

  • NFA Interpretive Notice

    The Commodity Futures Trading Commission’s Statement of Acceptable Practices mandates that covered firms adopt and implement an appropriate ethics training plan. The National Futures Association’s Interpretive Notice regarding Ethics Training provides further guidance on how firms can meet their ethics training requirements. To briefly summarize the Interpretive Notice, there are six elements that you should consider:

    1. Firms should have a written procedure in place that outlines their ethics training program. A suggested template is available here.

    2. Ethics training content should include the topics required by the CFTC’s Statement of Acceptable Practices. Exchange Analytics´ programs fully meet all standards required.

    3. Training providers must have at least three years of relevant industry or pedagogical experience in the field, be qualified, and not be subject to any investigations or bars from registration. Exchange Analytics is a fully qualified ethics training provider.

    4. Training format may be through a variety of media; Exchange Analytics´ Internet delivered courses are fully acceptable.

    5. Frequency of training may be determined by the firms, and the NFA Interpretive Notice makes it clear that formal training can appropriately be offered less frequently than informal training. Exchange Analytics´ training programs are formal training programs. We suggest that Initial training be taken within six months of registration, and Periodic training be taken at least every three years. This is what the CFTC previously required under CFTC Rule 3.34 and we believe that this training schedule is reasonable if Exchange Analytics´ courses are used.

    6. Documentation must be maintained by the member firm proving that it has complied with ethics training for its registrants