Three-quarters of U.S. Futures Commission Merchants use Exchange Analytics courses to help meet their regulatory training needs. We also serve Independent and Guaranteed Introducing Brokers, Commodity Trading Advisors, Commodity Pool Operators, Retail Foreign Exchange Dealers, Swap Dealers and Major Swap Participants, as well as Money Service Businesses and Non-bank Residential Mortgage Lenders and originators. The courses below are available immediately; Exchange Analytics also develops specialized courses to meet the individualized needs of its corporate customers.
Anti-Money Laundering (AML) Training
The USA Patriot Act of 2001 requires NFA-member firms to have in place Anti-Money Laundering (AML) compliance programs that, among other things, provide for annual training for appropriate employees.
Initial and Periodic Ethics Training
The CFTC issued a Statement of Acceptable Practices mandating 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 their ethics training requirements.
Cybersecurity (Information Systems Security) Training
NFA member firms must provide appropriate employees with Information Systems Security (Cybersecurity) training upon hiring and periodically during their employment. Since a review of each firm’s Information Systems Security Programs (ISSP) is required to be performed at least every twelve months, we highly recommend that training be performed every twelve months as part of the member’s adherence to its ISSP.
Customer Protection Rule Training
The Risk Management Program for Futures Commission Merchants (17 CFR 1.11), also known as the Customer Protection Rule, requires clearing FCMs to establish, maintain and enforce a system of risk management policies and procedures, maintain written risk management policies and procedures, have the risk management program and written policies approved in writing by the FCM’s governing body and distributed to supervisory personnel, and establish a risk management unit that provides quarterly reports to senior management.
Identity Theft Prevention Training
SEC Regulation S-ID along with CFTC Subpart C, enacted in 2013, require entities that qualify as either “financial institutions” or “creditors” to adopt programs to identity and address the risk of identity theft. Covered entities include SEC-regulated broker-dealers, investment advisers and certain investment companies; and CFTC-regulated entities that hold transaction accounts including futures commission merchants, retail foreign exchange dealers, commodity trading advisors, commodity pool operators, introducing brokers, swap dealers or major swap participants.
Additionally, we would be delighted to have relevant staff at FCMs review the Customer Protection Rule course. Please contact Larry Israel at email@example.com or call Exchange Analytics at 847-266-7602 to arrange for complimentary access.