InstructorTerri Hays
TypeOnline Course
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Tuition Options


PracticeEdge Elite™ Not included

Standard Tuition $400 US

Senior Fellow Patricia Cushing, CPA, Director, Compliance, National Futures Association

With over 4,000 member firms, the NFA must focus limited resources when determining which firms to audit. In 2006, the NFA enhanced the risk management system, Risk Assessment Priority Program (RAPP), to be able to more efficiently and effectively identify targets for an audit. The NFA wanted to take advantage of the advancements in technology and made many of the segregated systems interact with each other in order to collect more data to feed into the Risk Management System. The system is able to look at different risk factors that take into account different aspects of a firm’s operations as well as pull together information from outside reporting services to identify which firms pose the highest risk.
Generally, the NFA audits CPOs and CTAs every 3-5 years but will conduct more frequent audits if risk factors deem necessary. In fact, one of the risk factors is how long since the last audit.


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Students shall learn the following within this Course:

  • The NFA Audit Process
  • Risk-Based Audit Selection
  • How to Prepare for an NFA Audit
  • NFA Audit Process
  • Areas of Focus
  • Bylaw 1101: Due Diligence
  • Prohibition on pools loaning money to CPOs or Affiliates
  • Common Audit Deficiencies
  • Registration and Proficiency Requirements
  • CPO and CTA Registration Exemptions
  • Commodity and Exchange Act, Section 4m(1) and Section 4m(3)
  • CFTC Regulation 4.14(a)(8)
  • CFTC Regulation 4.5 and 4.6
  • Registration options and process
  • Enrollment
  • Registration
  • Proficiency Exam
  • NFA Examination & Enforcement: Disclosure Documents
  • Trading Program/Pool Investment Program
  • Conflicts of Interest and Litigation
  • NFA Examination and Enforcement: Performance Reporting

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Senior Fellow:

  • Patricia Cushing, CPA, Director, Compliance, National Futures Association


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Accreditation Information

CLE Information

Credit Hours: 3
Subject Area: Professional Practice
States: Contact Curriculum Advisor For More Information

CPE Information

Credit Hours: 6
Subject Area: Accounting
States: Contact Curriculum Advisor For More Information


Course ID Number:  7603


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Alabama: Approval of all web based programs is limited to a maximum of 6.0 credits.

Arizona: Does not approve or accredit CLE activities for the Mandatory Continuing Legal Education requirement. RCA programs may qualify for credit based on the requirements outlined in the MCLE Regulations and Ariz. R. Sup. Ct. Rule 45.

Iowa: The approval is for one year from recorded date. Does not approve of Audio-only On-Demand Webcasts.

Missouri: On-demand web programs are restricted to six hours of self-study credit per year. Self-study may not be used to satisfy the ethics requirements. Self-study can not be used for carryover credit.

New Hamphsire: The approval is for three years from recorded date.

New Mexico: On-Demand web programs are restricted to 4.0 self-study credits per year.

New York: Newly admitted attorneys may not take non-traditional course formats such as on-demand Web Programs or live Webcasts for CLE credit. Newly admitted attorneys not practicing law in the United States, however, may earn 12 transitional credits in non-traditional formats.

North Carolina: A maximum of 4 credits per reporting period may be earned by participating in on-demand web programs.

Ohio: To confirm that the web program has been approved, please refer to the list of Ohio’s Approved Self Study Activities at Online programs are considered self-study. Ohio attorneys have a 6 credit self-study limit per compliance period. The Ohio CLE Board states that attorneys must have a 100% success rate in clicking on timestamps to receive ANY CLE credit for an online program.

Oklahoma: Up to 6 credits may be earned each year through computer-based or technology-based legal education programs.

Pennsylvania: PA attorneys may only receive a maximum of four (4) hours of distance learning credit per compliance period. All distance learning programs must be a minimum of 1 full hour.

Rhode Island: Audio Only On-Demand Web Programs are not approved for credit. On-Demand Web Programs must have an audio and video component.

Tennessee: The approval is for the calendar year in which the live program was presented.

Virginia: All distance learning courses are to be done in an educational setting, free from distractions.

Wisconsin: Ethics credit is not allowed. The ethics portion of the program will be approved for general credit. There is a 10 credit limit for on-demand web programs during every 2-year reporting period. Does not approve of Audio-only On-Demand Webcasts.

Iowa, Mississippi, Oklahoma, and Wisconsin DO NOT approve Audio Only On-Demand Web Programs.

If you have already received credit for attending some or the entire program, please be aware that state administrators do not permit you to accrue additional credit for repeat viewing even if an additional credit certificate is subsequently issued.

If applicable, the RCA will apply for credit in your state upon request.