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About Ethics Requirements

Exchange Analytics Inc.

Ethics Training is a requirement for Registrants with the National Futures Association (NFA). The Commodity Futures Trading Commission (CFTC) has issued a Statement of Acceptable Practices, which mandates that each firm adopt and implement an appropriate ethics training plan.

The NFA has issued an Interpretive Notice regarding Ethics Training, which provides further guidance to firms regarding how to meet their ethics training requirements. To briefly summarize the Interpretive Notice, there are six elements that you should be aware of when choosing how to meet this requirement.

  1. Firms should have written procedure in place, outlining their ethics training program. A suggested template is available by clicking here.
  2. Content should be included in ethics training that meets the topics required by the Statement of Acceptable Practices. Exchange Analytics´ programs fully meet all standards required. Training outlines for the Periodic program and for the Initial program are available by clicking here: (Periodic Program Outline and Initial Program Outline)
  3. Training Providers must have at least three years of relevant industry or pedagogical experience in the field, be qualified, and are not subject to any investigations or bars from registration. Exchange Analytics is a fully qualified ethics training provider. Please see our Ethics Training Provider Qualifications.
  4. Training format may be through a variety of media, and Exchange Analytics´ Internet delivered courses are fully acceptable.
  5. Frequency of training may be determined by the firms, but the NFA Interpretive Notice makes it clear that formal training could appropriately be offered less frequently than informal training. Exchange Analytics´ training programs are formal training programs that address all topics required by the CFTC´s Statement of Acceptable Practices, and we have suggested that Initial training be taken within 6 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 their Registrants. Exchange Analytics makes this extremely easy by maintaining all records of Registrants who have ever taken our training courses, and we report all information to firms on a weekly basis. Records are available instantaneously for audit purposes, and Exchange Analytics is recognized throughout the industry as providing the best customer and record-keeping services.

Our ethics training courses are competitively priced at $35 for the Periodic ethics program and $75 for the Initial ethics course. Volume discounts as well as Ethics Training/Anti-Money Laundering training packages are available. Prices include reporting, certification, record-keeping, and everything you´ll need to prove compliance for regulatory purposes.

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