ARTICLE
6 October 2020

NFA Provides Relief From On-Site Inspection Requirement

CW
Cadwalader, Wickersham & Taft LLP

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Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
NFA provided relief to members from the requirement to conduct on-site annual inspections of their branch offices and guaranteed introducing brokers.
United States Coronavirus (COVID-19)
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NFA provided relief to members from the requirement to conduct on-site annual inspections of their branch offices and guaranteed introducing brokers ("IBs"). NFA stated that while the annual inspection requirement remains in effect, and inspections must be completed by December 31, 2020, the inspections may be conducted remotely. Additionally, NFA stated that members will not be obligated to conduct an on-site inspection the next calendar year in order to be in compliance with NFA Interpretive Notice 9019 - Compliance Rule 2-9: Supervision of Branch Offices and Guaranteed IBs and Interpretive Notice 9053 - Forex Transactions, provided that their risk assessments indicate that a remote inspection is appropriate.

Primary Sources

  1. NFA Notice I-20-35: Coronavirus Update-Relief from the On-Site Annual Inspection of Branch Offices and Guaranteed IBs

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