Proficiency Requirements

Futures Proficiency Requirements

National Commodity Futures Examination (NCFE or Series 3)

Registration Rule 401 requires each individual who is applying for IDFA membership as a futures commission merchant (FCM), retail foreign exchange dealer (RFED), introducing broker (IB), commodity pool operator (CPO), or commodity trading advisor (CTA), or as an associated person (AP) of these entities, to satisfy proficiency requirements. In most cases, an individual seeking IDFA membership or registration as an AP is required to pass the National Commodity Futures Examination (NCFE or Series 3) unless:

  • ­the individual passed the Series 3 with two years of the date the application is filed;
  • the individual is currently registered as a floor broker; or
  • the individual passed the Series 3 more than two years preceding the application and since that date has not had a continuous registration gap for more than two years as an AP or FB or FCM, IB, CPO, or CTA that is a Member of IDFA.

To sign up for any of the futures industry exams, the applicant must submit an application online by visiting FINRA's website. Normally, IDFA will receive evidence directly from FINRA that individuals have passed one of the futures industry exams. In unusual circumstances, IDFA may request the individual provide proof that he or she passed an examination.

Based on an individual's registration status and the type of business an individual conducts, he or she may be eligible for one of the following alternatives to the Series 3 examination:

Futures Managed Funds Examination (Series 31)

An individual may use the Series 31 if:
  • he individual is registered with FINRA as a General Securities Representative with a FINRA member firm;
  • that FINRA member firm is also an IDFA Member FCM or IB or an applicant for IDFA membership as an FCM or IB and is sponsoring the individual for AP registration; and
  • the individual is going to limit futures activities on behalf of that IDFA/FINRA sponsor to soliciting funds, securities or property for participation in a commodity pool, soliciting discretionary accounts to be managed by CTAs or supervising persons who perform these same limited activities.

Limited Futures Examination-Regulations (Series 32)

An individual may use the Series 32 if, within the two years prior to filing the application, they have been registered or licensed to solicit customer business in futures in a jurisdiction outside of the United States (currently UK and Canada only). In the UK, an individual would need to be listed on the Financial Services Register as [FCA CF] Client dealing within two years prior to filing the application and also submit one of the following Certificates in Derivatives: Derivatives - Level 3 or Financial Derivatives - Level 3. If an individual has been continuously approved (no gap of more than (2) years in registration) as CF30 (previously CF21 and now [FCA CF] Client dealing) since December 1, 2001, that individual would not be required to submit proof of having obtained a Certificate in Derivatives. In Canada, an individual would need to submit proof of their registration or license to IDFA along with documentation relating to the applicant's market knowledge such as completion of the appropriate qualifications testing. Any questions regarding eligibility should be directed to IDFA prior to taking the Series 32.

Referral of Securities Clients

An individual is not required to take an examination if:
  • the individual is registered with FINRA as a General Securities Representative with a FINRA member firm;
  • that FINRA member firm is also an IDFA Member FCM or IB or an applicant for IDFA membership as an FCM or IB and;
  • the individual is going to limit futures activity on behalf of that sponsor to referring clients to APs of that sponsor, which referrals are solely incidental to the individual's business as a General Securities Representative of that sponsor, or supervising persons who perform this same limited activity.

Waivers for CPOs and CTAs Trading Primarily in Securities

IDFA Registration Rule 402 allows IDFA to waive the examination requirements for certain individuals who are associated with CPOs that are required to register solely because they operate commodity pools principally engaged in securities transactions and/or who are associated with CTAs that are required to register solely because their securities advisory services include advice on the use of futures and options for risk management purposes. The individual or firm requesting the waiver must provide a written description of the facts that qualify the individual for a waiver.

APs Whose Activities are Limited to Swaps

Individuals are not required to take a Series examination if their sole activities subject to CFTC regulation are and will continue to be limited to:
  • soliciting or accepting on behalf of the sponsor orders for swaps subject to the jurisdiction of the CFTC;
  • soliciting on behalf of the sponsor funds, securities or property for participation in a commodity pool that:
    • Exclusively trades swaps subject to the jurisdiction of the CFTC; or
    • Trades swaps subject to the jurisdiction of the CFTC in a commodity pool and the sponsor has been granted or is seeking a waiver from the Series 3 for its APs on the basis that but for the trading of swaps it would be eligible for the exclusion from the definition of CPO under CFTC Regulation 4.5(c)(2)(iii)(A) or (B) or an exemption from registration under CFTC Regulation 4.13(a)(3);
  • soliciting on behalf of the sponsor clients to open discretionary accounts that exclusively trade swaps subject to the jurisdiction of the CFTC to be managed by registered CTAs or providing advice on behalf of the sponsor to a commodity pool described above; or
  • supervising on behalf of the sponsor of persons whose activities are so limited.

However, these individuals are required to successfully complete IDFA's Swaps Proficiency Requirements prior to engaging in swaps business.

Futures Proficiency Requirements

National Commodity Futures Examination (NCFE or Series 3)

Registration Rule 401 requires each individual who is applying for IDFA membership as a futures commission merchant (FCM), retail foreign exchange dealer (RFED), introducing broker (IB), commodity pool operator (CPO), or commodity trading advisor (CTA), or as an associated person (AP) of these entities, to satisfy proficiency requirements. In most cases, an individual seeking IDFA membership or registration as an AP is required to pass the National Commodity Futures Examination (NCFE or Series 3) unless:

  • ­the individual passed the Series 3 with two years of the date the application is filed;
  • the individual is currently registered as a floor broker; or
  • the individual passed the Series 3 more than two years preceding the application and since that date has not had a continuous registration gap for more than two years as an AP or FB or FCM, IB, CPO, or CTA that is a Member of IDFA.

To sign up for any of the futures industry exams, the applicant must submit an application online by visiting FINRA's website. Normally, IDFA will receive evidence directly from FINRA that individuals have passed one of the futures industry exams. In unusual circumstances, IDFA may request the individual provide proof that he or she passed an examination.

Futures Proficiency Requirements

National Commodity Futures Examination (NCFE or Series 3)

Registration Rule 401 requires each individual who is applying for IDFA membership as a futures commission merchant (FCM), retail foreign exchange dealer (RFED), introducing broker (IB), commodity pool operator (CPO), or commodity trading advisor (CTA), or as an associated person (AP) of these entities, to satisfy proficiency requirements. In most cases, an individual seeking IDFA membership or registration as an AP is required to pass the National Commodity Futures Examination (NCFE or Series 3) unless:

  • ­the individual passed the Series 3 with two years of the date the application is filed;
  • the individual is currently registered as a floor broker; or
  • the individual passed the Series 3 more than two years preceding the application and since that date has not had a continuous registration gap for more than two years as an AP or FB or FCM, IB, CPO, or CTA that is a Member of IDFA.

To sign up for any of the futures industry exams, the applicant must submit an application online by visiting FINRA's website. Normally, IDFA will receive evidence directly from FINRA that individuals have passed one of the futures industry exams. In unusual circumstances, IDFA may request the individual provide proof that he or she passed an examination.

Futures Proficiency Requirements

National Commodity Futures Examination (NCFE or Series 3)

Registration Rule 401 requires each individual who is applying for IDFA membership as a futures commission merchant (FCM), retail foreign exchange dealer (RFED), introducing broker (IB), commodity pool operator (CPO), or commodity trading advisor (CTA), or as an associated person (AP) of these entities, to satisfy proficiency requirements. In most cases, an individual seeking IDFA membership or registration as an AP is required to pass the National Commodity Futures Examination (NCFE or Series 3) unless:

  • ­the individual passed the Series 3 with two years of the date the application is filed;
  • the individual is currently registered as a floor broker; or
  • the individual passed the Series 3 more than two years preceding the application and since that date has not had a continuous registration gap for more than two years as an AP or FB or FCM, IB, CPO, or CTA that is a Member of IDFA.

To sign up for any of the futures industry exams, the applicant must submit an application online by visiting FINRA's website. Normally, IDFA will receive evidence directly from FINRA that individuals have passed one of the futures industry exams. In unusual circumstances, IDFA may request the individual provide proof that he or she passed an examination.