Frequently Asked Questions
Ethics Requirements
We highly recommend that new Registrants of the National Futures Association take an Initial ethics course within six months of registration, and that a Periodic course be taken every three years thereafter. The provisions of Section 4p(b) of the Commodity Exchange Act ("Act") (7 U.S.C. 6p(b) (1994)) set forth requirements regarding training of Registrants as to their responsibilities to the public. This section of the Act requires the Commodity Futures Trading Commission ("CFTC") to issue regulations requiring new Registrants to attend ethics training sessions within six months of registration, and all Registrants to attend such training on a periodic basis.
TopThe cost per-person for the Periodic ethics couse is $35 and the Initial ethics course is $75. Our new AML course is $25. Our price includes everything - the course itself, certification of completion, reports to your firm, and all record keeping.
There is no minimum time you must spend on the course and you can take as long as you want to finish. The average times spent, however, are 1 hour for the Periodic course and between 2 - 3 hours for the Initial.
How often does training have to be taken?
Firms can decide how frequently ethics training is required based on their business model. According to the NFA's Interpretive Notice regarding ethics training, more formal training could appropriately be offered less frequently. We highly recommend that new Registrants of the National Futures Association take an Initial ethics course within six months of registration, and that a Periodic course be taken every three years thereafter.
Exchange Analytics' ethics training is a formal, web-based course, which takes the user through topics required by the Statement of Acceptable Practices. Under the previous ethics training rule (CFTC Rule 3.34), Initial training was required within six months of registration, and Periodic training required every three years thereafter. While the NFA Interpretive Notice does not specifically mandate a training interval, we believe that the formal training that Exchange Analytics offers can be offered on the same interval as previously required by Rule 3.34. While it is important to emphasize that this choice is entirely the individual firm's decision, virtually all of the major firms in the industry have continued to offer formal training in the same interval as previously required by Rule 3.34.
Does my firm have to provide ethics training for my registrants?
Your firm is responsible for ensuring that Registrants retain an up-to-date knowledge of their obligation to the public to observe "just and equitable principles of trade". Your Registrants' participation in Exchange Analytics ethics programs will prove that your firm has fulfilled that responsibility.
What will my firm need to provide to prove compliance to a regulatory body?
The National Futures Association states in its Interpretive Notice regarding ethics training: "Maintaining documentation that the firm has complied with its ethics training procedures is a crucial element of an acceptable ethics training program. Firms that utilize more formal training programs should keep records showing who obtained the training, the date of training and any materials used."
There are four things that your firm (or you if you are a sole proprietor) should have when being audited:
- Written procedures that outlines your ethics-training program. While your firm should have a plan that meets its needs, we have supplied a sample written procedures prototype for your convenience.
- Materials used for training. Training content should address the topics required by the Statement of Acceptable Practices, and Exchange Analytics' programs are guaranteed to meet all requirements. Our Periodic Course Outline and our Initial Course Outline are available (by clicking them) and will serve as the documentation you will need.
- Records showing who obtained the training at your firm, and the date of that training. Exchange Analytics supplies all records necessary to absolutely prove that training was accomplished - immediately after completion of the program a certification email is generated to the individual who took training. Every Thursday a formal certificate is mailed to the compliance coordinator at the firm, and periodically cumulative summary reports are also sent to the firm. Exchange Analytics maintains all records in our database and we can instantaneously provide records for you anytime you need them.
- Qualifications of ethics training providers. Ethics training providers have to be qualified and firms must obtain proof that the provider has completed relevant proficiency testing and has three years of relevant industry experience, or similar experience. Providers may not be subject to any investigations or bars from registration. Exchange Analytics is a fully qualified provider and our Qualifications Document will prove this to any regulatory body.
Do I have to keep records showing compliance?
According to the NFA's Interpretive Notice regarding ethics training, "Maintaining documentation that the firm has complied with its ethics training procedures is a crucial element of an acceptable ethics training program."
Exchange Analytics considers record-keeping one of our most important services. All records are kept electronically and maintained by Exchange Analytics as a third party who can immediately verify that training was accomplished. Certificates are emailed to the Registrants immediately after completion, and every Thursday reports and certificates are sent to the appropriate person at the firm responsible for training. Periodically cumulative training reports are sent to firms in either paper or electronic formats, and are always available instantaneously upon request. This information proves your firm has met its training requirements.
Why should I use Exchange Analytics as my ethics training provider?
Exchange Analytics is the largest provider of ethics training. We assure you that our programs have met, and will continue to meet, all standards established to prove that you have met your obligations under the new regulatory framework.
We have provided ethics training to the majority of the world's largest securities firms, and well over 1,000 other firms. Exchange Analytics has consistently set the curve for convenient and easy course delivery and reporting systems. We will continue to provide the same level of service and assurance that all federal requirements are met.
Where can I view the National Futures Association Interpretive Notice concerning Ethics Training?
The Interpretive Notice is available directly on the NFA's web site.
Ethics Requirements
Our courses are not tests or exams. They are an engaging exercise where information is presented which covers all topics of the CFTC's Statement of Acceptable Practices, and interactively engages the participant in different views and perspectives of ethical and legal dilemmas. At the conclusion of the courses the participant is asked to click an "electronic signature" button, which serves as evidence that the course was taken completely and in good faith by the person who enrolled.
Do I have to take the course in one sitting?
Courses can be taken in as many sittings as desired - you can quit the program at any time and re-enter where you left off. Courses are available 24 hours a day, 7 days a week.
What is the difference between the Initial and Periodic programs?
The Initial program is intended for New Registrants, or for Registrants who have never taken an ethics-training course. The Periodic program is designed to be a "refresher" course, and satisfy the periodic, ongoing training requirement. The Initial course has a more thorough emphasis on Federal laws and rules and regulations of the CFTC, the NFA, and self-regulatory bodies. We highly recommend that new Registrants of the National Futures Association take an Initial ethics course within six months of registration, and that a Periodic course be taken every three years thereafter.
There is no minimum time you must spend on the course and you can take as long as you want to finish. The average times spent are 1 hour for the Periodic course and between 2 - 3 hours for the Initial.
What happens when I finish the course?
Upon completion of the course you will be asked to click an "electronic signature" button, which serves as attestation that you completed the course by yourself and in good faith. Immediately after clicking this "electronic signature" an email will be generated to you, which certifies that you have completed the training. An electronic record will also be generated directly to Exchange Analytics and then stored in our database for record keeping. Every week we send out paper certificates to the compliance coordinator at the firm you are associated with.
Do Exchange Analytics' ethics programs satisfy my ongoing training requirements?
Exchange Analytics is the largest provider of ethics training, and has been providing this service since 1994. Our training programs met all requirements mandated by former CFTC Rule 3.34. Our programs meet, and will continue to meet, all standards established to prove that you have met your obligations under the new regulatory framework.
How is Exchange Analytics qualified to provide these programs?
Exchange Analytics is a fully qualified provider of this training, and we meet all standards under NFA Compliance Rule 2-9. Exchange Analytics' programs were substantially written by Lawrence D. Israel. He has been continuously registered from March 11, 1981 through the present, and has been a member of the Chicago Board of Trade from 1976 through the present. During that time Mr. Israel has been extensively involved in the futures industry, serving on a variety of committees at the CBOT, including Arbitration and Education. Mr. Israel has served as an Arbitrator for the National Futures Association, as well as an expert witness in both Federal Court and arbitrations in disputes involving futures trading. Lawrence D. Israel (NFA ID 0019703) is not subject to any investigations or bars from registration. He has no regulatory actions or other disciplinary history.
Why should I use Exchange Analytics' ethics programs?
Exchange Analytics is the largest provider of ethics training. We assure you that our programs have met, and will continue to meet, all standards established to prove that you have met your obligations under the new regulatory framework.
We have provided ethics training to the majority of the world's largest securities firms, and well over 1,000 other firms. Exchange Analytics has consistently set the curve for convenient and easy course delivery and reporting systems. We will continue to provide the same level of service and assurance that all federal requirements are met.
Technical Questions and Troubleshooting
What do I need on my computer to run the programs?
Virtually all computers capable of connecting to the Internet will do the job - A minimum of Microsoft Explorer 5.X , Netscape Navigator 5.x is required, or AOL 4.0 is required. Almost all computers have these minimum specifications, and in case yours doesn't they are available for free download.
What kind of Internet connection do I need to take the course?
You should have a minimum connection speed of 28 K (simple dial-up). A higher speed connection, however, may enhance your enjoyment of the program and we recommend using the fastest Internet connection available to you. Our program is hosted on a network that is delivered through a T1 connection.
How do I navigate through the program?
Each screen has navigational buttons that allow you to go forward, backward or quit the program.
If my computer freezes, or I am disconnected from the Internet, is my work saved?
Your progress in the course will be saved if you encounter any computer lock up or shut down. By re-entering the course with your user name and password, you will return to the last point you accessed in the course.
No. Your Corporate ID or unique Access Code gives you original access the program. If you are re-entering a course already in progress, you must enter the course through the Re-enter Course link (also at the top of each page). Here, you will enter your User Name and Password (both of which will be determined in the original registration process).
What happens if the program appears to freeze, or I get an error message?
Occasionally electronic communication on the Internet is interrupted. We suggest that you try the following as a first step:
- In Microsoft Explorer - Click the "Refresh" icon. If this does not help, click the browser back button (located on the top of the screen in the Explorer Toolbar), and then click Continue.
- In Netscape Navigator - Click the "Reload" icon on the browser toolbar. If this does not help, click the browser back button (located on the top of the screen in the Navigator Toolbar), and then click the browser forward button.
Our server, however, always retains your place on the last point that you have reached in the program, so even in the event of a communication problem you will not lose your work.
- Traffic on the Internet or your network may be extremely heavy, and consequently has slowed the connection speed. This is a common Internet problem, particularly during late afternoons during the week. To avoid this problem, we would advise that you take the course when the Internet traffic is reduced.
- The connection for a particular screen is incomplete, and needs to be refreshed. To do this, simply click Refresh on the top browser toolbar on Internet Explorer, or Reload on Netscape Navigator.
How can I contact Exchange Analytics for Technical Support?
Exchange Analytics Technical Support may be accessed by email, fax and by telephone. We will be happy to assist you. Our normal business hours are every weekday between 8 a.m. - 5 p.m. CST.
Email: exch@xanalytics.com
Fax: 847-266-8030.
Telephone: 800-823-8442.