NFA amendments to NFA Notice 9002 - Registration Requirements; Branch Offices that modify the definition of "branch office" to exclude certain locations that are part of a hybrid work-from-home environment will go into effect on September 23, 2021.
As previously covered, the amended definition of "branch office" excludes locations "where one or more APs [associated persons] from the same household live or rent/lease," if:
- the location is not held open to the public as the member firm's office would be;
- the location is not used for the purpose of in-person customer meetings or the physical handling of customer funds; and
- all CFTC- and NFA-required records that are made in the location can be accessed at the member firm's main office or the relevant branch office.
NFA explained that once the amendments go into effect, the currently effective relief provided under NFA Notice I-20-12 ("Coronavirus Update-NFA Branch Office Requirements") will expire.
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