Ethics Training Requirements
- Q: Which course do I need?
- Q: What is the difference between the Initial and Periodic ethics training courses?
- Q: How much do the ethics courses cost?
- Q: How long do the courses take?
- Q: How often does training have to be taken?
- Q: Does my firm have to provide ethics training for my registrants?
- Q: What will my firm need to provide to prove compliance to a regulatory body?
- Q: Do I have to keep records showing compliance?
- Q: Why should I use Exchange Analytics as my ethics training provider?
- Q: How is Exchange Analytics qualified to provide these programs?
- Q: Where can I view the National Futures Association Interpretive Notice concerning Ethics Training?
AML Training Requirements
- Q: Who should take AML training?
- Q: How much doe the AML course cost?
- Q: How long does the AML course take?
- Q: How often does AML training have to be taken?
- Q: Do all employees have to take AML training?
- Q: What will my firm need to provide to prove compliance to a regulatory body?
- Q: Do I have to keep records showing compliance?
- Q: Why should I use Exchange Analytics as my AML training provider?
- Q: Where can I view information about the requirements of the USA PATRIOT Act?
About Exchange Analytics´ Online Ethics and AML Courses
- Q: Are these tests?
- Q: How much do the courses cost?
- Q: How long do the courses take?
- Q: Do I have to take a course in one sitting?
- Q: What is the different between the Initial ethics and Periodic ethics programs?
- Q: What happens when I finish a course?
- Q: Do Exchange Analytics´ ethics programs satisfy my ongoing ethics training requirements?
- Q: How is Exchange Analytics qualified to provide these programs?
- Q: Why should I use Exchange Analytics as my ethics and AML training provider?
Technical Questions and Troubleshooting
- Q: What do I need on my computer to run the programs?
- Q: What kind of Internet connection do I need to take the course?
- Q: How do I navigate through the program?
- Q: If my computer freezes, or I am disconnected from the Internet, is my work saved?
- Q: How do I quit the course in progress and go back to it later?
- Q: What happens if the program appears to freeze, or I get an error message?
- Q: How can I contact Exchange Analytics for Technical Support?
Ethics Training Requirements
Q: Which course do I need?
A: 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.
Q: What is the difference between the Initial and Periodic ethics training courses?
A: 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 satisfies 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 one to three years thereafter.
Q: How much do the ethics courses cost?
A: The Periodic and Initial ethics courses are $35 and $75 respectively. Our prices include everything - the course itself, certification of completion, reporting results to your firm, and all record keeping. Our courses are the most convenient and cost effective programs available.
Q: How long do the courses take?
A: 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 hours for the Initial.
Q: How often does training have to be taken?
A: Firms can decide how frequently ethics training is required based on their business model. 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 one to three years thereafter. According to the NFA´s Interpretive Notice regarding ethics training, more formal training could appropriately be offered less frequently.
Exchange Analytics´ ethics training is a formal, web-based course, which takes the user through topics required by the CFTC´s 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, irtually 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.
Q: Does my firm have to provide ethics training for my registrants?
A: 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.
Q: What will my firm need to provide to prove compliance to a regulatory body?
A: 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 and our Initial Course Outlines 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.
Q: Do I have to keep records showing compliance?
A: 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.
Q: Why should I use Exchange Analytics as my ethics training provider?
A: 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.
Q: How is Exchange Analytics qualified to provide these programs?
A: Exchange Analytics´ programs are overseen 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 was chairman of the Associate Members Committee (financial traders) from 1992-1994, and has served as an Arbitrator for the National Futures Association.
Mr. Israel is an adjunct lecturer of futures and options at Northwestern University, and has served as an expert in both Federal Court and arbitrations in disputes involving futures trading, as well as for the US Department of Justice. He holds a B.S. from the University of Illinois and a MBA from the University of Chicago.
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.
Q: Where can I view the National Futures Association Interpretive Notices concerning Ethics Training?
A: The Interpretive Notice is available directly on the NFA´s web site.
AML Training Requirements
Q: Who should take AML training?
A: All NFA registered Futures Commission Merchants (FCMs), Introducing Brokers (IBs) and NASD broker/dealers (BDs) are required to have an anti-money laundering (AML) compliance in place, which includes the ongoing obligation to provide ongoing education and training for all appropriate personnel at the firm.
Q: How much doe the AML course cost?
A: Our AML courses are $25 each. This includes everything - the course itself, certification of completion, reporting results to your firm, and all record keeping.
Q: How long does the AML course take?
A: There is no minimum time you must spend on the course and you can take as long as you want to finish. The average time spent, however, is about 40 minutes for the AML training.
Q: How often does AML training have to be taken?
A: At a minimum, a regulated firm should provide annual training on the firm´s policies and procedures, the relevant federal laws and regulatory AML requirements.
Q: Do all employees have to take AML training?
A: Regulated financial institutions must provide ongoing AML education and training for all appropriate personnel. While this is up to the discretion of the firm, it is our recommendation that any employee involved in the flow of funds or account documentation should take an AML training program.
Q: What will my firm need to provide to prove compliance to a regulatory body?
A: Most regulatory bodies require that an outline of the program materials be available, as well as record indicating that training has been accomplished. Exchange Analytics´ provides an AML course outlines as well as all information necessary to prove that a person has participated in the AML training course.
Q: Do I have to keep records showing compliance?
A: Yes. Self-regulatory and federal regulators will require that regulated financial institutions provide records showing compliance.
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.
Q: Why should I use Exchange Analytics as my AML training provider?
A: As the one of the largest providers of compliance training, Exchange Analytics has consistently set the curve for effective, efficient and convenient online course delivery. Our courses are written by compliance experts and do an excellent job of reminding your employees of their obligations under the USA PATRIOT Act. Well over 1,000 firms have satisfied their AML training requirements with us.
Q: Where can I view information about the requirements of the USA PATRIOT Act?
A: You can view more about the requirements of the USA PATRIOT Act by clicking this link.
About Exchange Analytics´ Online Ethics and AML Courses
Q: Are these tests?
A: Our courses are not tests or exams. They are an engaging exercise where information is presented 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.
Q: How much do the courses cost?
A: Exchange Analytics competitively prices our Periodic ethics training course at $35, our Initial ethics training course at $75, and our AML training course at $25.
Q: How long do the courses take?
A: 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 ethics course, about 2 hours for the Initial ethics course, and about 40 minutes for the AML training course.
Q: Do I have to take the course in one sitting?
A: 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.
Q: What is the difference between the Initial and Periodic ethics programs?
A: 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.
Q: What happens when I finish a course?
A: 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 Certificate of Completion will be generated and sent instantly 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 formal paper certificates to the compliance coordinator at the firm you are associated with.
Q: Do Exchange Analytics´ ethics programs satisfy my ongoing training requirements?
A: 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.
Q: How is Exchange Analytics qualified to provide these programs?
A: Exchange Analytics is a fully qualified provider of this training, and our ethics programs meet all standards under NFA Compliance Rule 2-9 and the CFTC´s Statement of Acceptable Practices criteria. Exchange Analytics´ programs are overseen 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 was chairman of the Associate Members Committee (financial traders) from 1992-1994, and has served as an Arbitrator for the National Futures Association.
Mr. Israel is an adjunct lecturer of futures and options at Northwestern University, and has served as an expert in both Federal Court and arbitrations in disputes involving futures trading, as well as for the US Department of Justice. He holds a B.S. from the University of Illinois and a MBA from the University of Chicago.
Q: Why should I use Exchange Analytics´ as my ethics and AML training provider?
A: As the one of the largest providers of compliance training to the futures industry, Exchange Analytics has consistently set the curve for effective, efficient and convenient online course delivery. Our courses are written by compliance experts and do an excellent job of both satisfying your regulatory training requirements.
Technical Questions and Troubleshooting
Q: What do I need on my computer to run the programs?
A: Virtually any computer connected to the Internet and with a standard browser will run our courses.
Q: What kind of Internet connection do I need to take the courses?
A: You should have a minimum connection speed of 28k (simple dial-up). A higher speed connection, however, may enhance your enjoyment of the programs and we recommend using the fastest Internet connection available to you. Our courses are hosted on a network that is delivered through redundant high speed commercial connections.
Q: How do I navigate through the program?
A: Each screen has navigational buttons that allow you to go forward, backward, review sections or quit the program.
Q: How do I quit the course If my computer freezes, or I am disconnected from the Internet, is my progress saved?
A: Your progress in the course is always saved at the last screen you viewed, regardless of whether your computer locked up or shut down, or if you accidentally get disconnected. By re-entering the course with your user name and password, you will return to the last point you accessed in the course.
Q: How do I quit the course in progress and go back to it later?
A: You can quit the program at any point by either clicking "Quit" or just by closing the browser window. Your place in the course will always be "bookmarked". To re-enter from where you left off, just click "Re-Enter Course in Progress" (at the top of the screen in the gray menu bar). Enter your user name and password and you will be transported right back to where you left off.
Q: What happens if the program appears to freeze, or I get an error message?
A: Occasionally electronic communication on the Internet is interrupted. We suggest that you first try clicking the browser "Refresh" 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 program you will not lose your work. For technical support please feel free to call us during business hours at 800-823-8442 or email at exch@xanalytics.com.
Q: How can I contact Exchange Analytics for technical support?
A: Exchange Analytics Technical Support may be access by email, fax or telephone. We will be happy to take call during normal business hours between 8 am - 5 pm CST and anytime via email.
Email: exch@xanalytics.com
Fax: 847-266-8030
Telephone: 800-823-8442
About Us:
Exchange Analytics is a leading supplier of web-based compliance courses, and is the world´s largest provider of Futures Ethics training courses, required by the Commodity Futures Trading Commission and the National Futures Association. Hundreds of firms also depend on Exchange Analytics´ Anti-Money Laundering training (AML) course to satisfy training requirements under the USA PATRIOT Act.
Special emphasis has been placed on sales support and liability exposure utilizing Exchange Analytics´ 60 years of experience in sales, branch management and trading in the Securities and Futures Industries, as well as service as arbitrators for the National Futures Association (NFA), and the Chicago Board of Trade.
Numerous experts contribute to our course development process, including a former Chief Counsel of the Commodity Futures Trading Commission´s Division of Trading and Markets, former senior Compliance Officers of the National Futures Association, and several high level Compliance Officers at some of the largest financial service firms in the world.