2025-11-13T13:51:51-06:00 2025-06-30 991856619 GRANT THORNTON ADVISORS LLC 171 N CLARK ST SUITE 200 CHICAGO IL 60601 990 2024-07-01 362960981 NATIONAL FUTURES ASSOCIATION NATI 3127811300 320 SOUTH CANAL SUITE 2400 CHICAGO IL 60606 DAVID HAWRYSZ SR VP, CFO, TREASURER 3127811385 2025-11-13 1 0 BRIDGET T ROCHE P00666837 3128560200 2024 2025-03-06 01:10:19Z DAVID HAWRYSZ 320 SOUTH CANAL SUITE 2400 CHICAGO IL 60606 154945104 0 X WWW.NFA.FUTURES.ORG X 1976 DE NFA IS A SELF-REGULATORY MEMBERSHIP ORGANIZATION FORMED TO MONITOR (CONTINUED IN SCHEDULE O) (CONTINUANCE OF PART I, LINE 1)AND MAINTAIN THE INTEGRITY OF THE DERIVATIVES TRADING INDUSTRY. 22 22 588 0 0 0 0 0 139107064 149565477 4550578 5379627 1385 0 143659027 154945104 0 0 0 0 102968773 107595461 0 0 0 35902881 37644100 138871654 145239561 4787373 9705543 241465991 252045557 76129197 71292770 165336794 180752787 X AS A CONGRESSIONALLY AUTHORIZED SELF-REGULATORY ORGANIZATION, NATIONAL FUTURES ASSOCIATION (NFA) IS THE SELF-REGULATORY ORGANIZATION FOR THE U.S. DERIVATIVES INDUSTRY, INCLUDING EXCHANGE TRADED FUTURES, RETAIL OFF-EXCHANGE FOREIGN CURRENCY (FOREX) AND (CONTINUED IN SCHEDULE O) (CONTINUANCE OF PART III, LINE 1)OTC DERIVATIVES (SWAPS). NFA HAS DEVELOPED AND ENFORCES RULES, PROVIDES PROGRAMS AND OFFERS SERVICES THAT SAFEGUARD MARKET INTEGRITY, PROTECT INVESTORS AND HELP OUR MEMBERS MEET THEIR REGULATORY RESPONSIBILITIES. 0 0 REGISTRATIONNFA SCREENS ALL FIRMS AND INDIVIDUALS WISHING TO REGISTER WITH THE CFTC AND BECOME NFA MEMBERS. NFA'S REGISTRATION DEPARTMENT PROCESSED 282 FIRM REGISTRATIONS AND OVER 4,428 INDIVIDUAL REGISTRATIONS.REGISTRATION INVESTIGATION CASES NFA'S REGISTRATION INVESTIGATIONS GROUP OPENED APPROXIMATELY 1,160 CASES. THESE INVESTIGATION CASES ARE DUE TO INFORMATION OBTAINED DURING NFA'S BACKGROUND CHECKS.(CONTINUED IN SCHEDULE O)(CONTINUANCE OF PART III, LINE 4A)INFORMATION CENTER NFA'S INFORMATION CENTER - A SERVICE NFA OFFERS TO MEMBERS AND THE INVESTING PUBLIC - RECEIVED 16,011 CALLS AND RESPONDED TO 4,175 EMAILS.ENFORCEMENT ACTIONS ENFORCEMENT OF NFA RULES IS CRITICAL TO THE EFFECTIVENESS OF THE SELF-REGULATORY PROCESS. IN FISCAL YEAR 2025: NFA'S BUSINESS CONDUCT COMMITTEE ISSUED 14 COMPLAINTS AGAINST 27 RESPONDENTS. A NUMBER OF THESE CASES INVOLVED MEMBERS AND ASSOCIATES WHO FAILED TO SUPERVISE, COOPERATE WITH NFA IN AN INVESTIGATION OR OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE OR COMPLY WITH RECORDKEEPING REQUIREMENTS.NFA'S DISCIPLINARY PANELS ISSUED 17 DECISIONS AND ORDERED 6 MEMBERSHIP BARS, 5 MEMBERSHIP SUSPENSION, AND NFA IMPOSED OVER $2.2 MILLION IN REGULATORY FINES. 0 0 0 1 0 0 0 1 0 1 0 0 1 1 1 1 0 0 0 1 0 0 0 0 0 0 0 0 1 0 0 0 0 1 0 0 0 0 0 0 0 0 0 1 0 0 1 588 1 0 0 0 0 0 0 1 0 X 22 22 0 0 0 0 1 1 1 1 1 0 0 1 1 1 1 1 1 1 1 0 CA X DAVID HAWRYSZ 3127811300 320 SOUTH CANAL SUITE 2400 CHICAGO IL 60606 SCOTT ANDERSEN BOARD MEMBER 1.00 0.00 X 31250 0 0 SETH BENDER BOARD MEMBER 1.00 0.00 X 30000 0 0 ANA BESKIN BOARD MEMBER 1.00 0.00 X 60000 0 0 TRABUE BLAND BOARD MEMBER 1.00 0.00 X 0 0 0 MICHAEL BURKE BOARD MEMBER 1.00 0.00 X 30000 0 0 GERALD CORCORAN CHAIR 1.00 0.00 X X 40000 0 0 ALICIA CRIGHTON BOARD MEMBER 1.00 0.00 X 0 0 0 MICHAEL DAWLEY BOARD MEMBER 1.00 0.00 X 60000 0 0 RONALD FILLER BOARD MEMBER 1.00 0.00 X 60000 0 0 ARTHUR HAHN BOARD MEMBER 1.00 0.00 X 60000 0 0 JULIE HOLZRICHTER BOARD MEMBER (THRU 2/2025) 1.00 0.00 X 0 0 0 ERNEST JAFFARIAN BOARD MEMBER 1.00 0.00 X 30000 0 0 THOMAS KADLEC BOARD MEMBER 1.00 0.00 X 35000 0 0 MARTIN LUECK BOARD MEMBER 1.00 0.00 X 35000 0 0 MARK MAURER BOARD MEMBER 1.00 0.00 X 30000 0 0 MARY MCDONNELL BOARD MEMBER 1.00 0.00 X 65000 0 0 CHARLOTTE MCLAUGHLIN BOARD MEMBER (THRU 2/2025) 1.00 0.00 X 0 0 0 KATHARYN MEYER BOARD MEMBER (AS OF 2/2025) 1.00 0.00 X 0 0 0 TAMEKA MORTON BOARD MEMBER (AS OF 2/2025) 1.00 0.00 X 0 0 0 RONALD OPPENHEIMER BOARD MEMBER 1.00 0.00 X 60000 0 0 TODD PETZEL BOARD MEMBER 1.00 0.00 X 63000 0 0 DEREK SAMMANN BOARD MEMBER (AS OF 2/2025) 1.00 0.00 X 0 0 0 DON THOMPSON BOARD MEMBER 1.00 0.00 X 30000 0 0 CONSTANCE WICK BOARD MEMBER 1.00 0.00 X 32500 0 0 THOMAS SEXTON PRESIDENT AND CEO 40.00 0.00 X 1238311 0 82260 REGINA THOELE SENIOR VICE PRESIDENT (THRU 2/2025) 40.00 0.00 X 762319 0 82523 CAROL WOODING SR.VP, GC, AND SECRETARY 40.00 0.00 X 769680 0 79260 EDWARD DASSO SENIOR VICE PRESIDENT 40.00 0.00 X 682048 0 53810 TIMOTHY MCHENRY SENIOR VICE PRESIDENT 40.00 0.00 X 738895 0 82260 DAVID HAWRYSZ SR. VP, CFO, AND TREASURER 40.00 0.00 X 678922 0 82763 KAREN WUERTZ SENIOR VICE PRESIDENT (THRU 2/2025) 40.00 0.00 X 573122 0 79242 MICHAEL OTTEN SENIOR VICE PRESIDENT, OTC 40.00 0.00 X 784614 0 76143 LAUREN BRINATI VP, ADMIN STRATEGY RISK 40.00 0.00 X 581034 0 63007 NANCY C BOHANON VICE PRESIDENT, HR 40.00 0.00 X 430840 0 78156 YVETTE CHRISTMAN VICE PRESIDENT (THRU 2/2025) 40.00 0.00 X 341764 0 61129 DALE SPOLJARIC VICE PRESIDENT, OTC 40.00 0.00 X 505603 0 79222 CLIFFE ALLEN MANAGING DIRECTOR, OTC 40.00 0.00 X 426989 0 34869 ALESSANDRA RICCARDI MANAGING DIRECTOR, OTC 40.00 0.00 X 405117 0 74267 CYNTHIA IOANNACCI ASSOC. GENERAL COUNSEL 40.00 0.00 X 367547 0 58733 ANNE JOVES ASSOCIATE GENERAL COUNSEL 40.00 0.00 X 395622 0 15402 JOSEPH HAWRYSZ MANAGING DIRECTOR, COMPLIANCE 40.00 0.00 X 372686 0 25846 DANIEL DRISCOLL SPECIAL ADVISOR 40.00 0.00 X 254098 0 68963 11060961 0 1177855 328 1 1 0 CLUNE CONSTRUCTION COMPANY 10 S RIVERSIDE PLAZA STE 2200 CHICAGO IL 60606 CONSTRUCTION 7771935 320 S CANAL TITLEHOLDER LLC 150 N RVSIDE PLZA STE 1800 CHICAGO IL 60606 RENT 1066258 ONE NY PLAZA CO LLC 250 VESEY ST 15TH FLOOR NEW YORK NY 10281 RENT 954122 OFFICE REVOLUTION LLC 2275 HALF DAY ROAD STE 100 BANNOCKBURN IL 60015 OFFICE FURNITURE 541540 MCDERMOTT WILL & EMERY LLP 444 W LAKE ST STE 4000 CHICAGO IL 60606 LEGAL SERVICES 323360 12 ASSESS. FEES & MARKET 900099 93460357 93460357 MEMBERSHIP DUES 900099 52563876 52563876 REGULATORY FINES 900099 2275200 2275200 REGISTRATION & TESTING 900099 968101 968101 ARBITRATION REVENUE 900099 32338 32338 265605 265605 149565477 5379627 5379627 154945104 149565477 0 5379627 9534213 394941 73805726 7451807 10942503 5466271 765035 96495 38238 5068796 19000 1432903 13367001 5434032 2605459 291744 6930355 EDUCATION & RECRUITMENT 1297231 DUES & SUBSCRIPTIONS 297811 145239561 24257217 32074370 40105196 46614421 4368589 3275865 3744153 4495318 46442305 19899431 30699034 26542874 104218934 106812054 0 0 34072868 32230655 241465991 252045557 12463340 9295893 11071827 10799146 52594030 51197731 76129197 71292770 X 165336794 180752787 165336794 180752787 241465991 252045557 X 9705543 6060939 -350489 X 0 1 X 1 0 0 0 0 142833776 38238 38238 0 38238 1 363308599 1118896 -355312838 9114657 0 22525030 4465166 18059864 8193632 6246843 1946789 15723643 9187422 6536221 26542874 RIGHT OF USE ASSET 25564789 ASSESSMENTS RECEIVABLE 6625990 ALL OTHER ASSETS 39876 32230655 ALL OTHER LIABILITIES 51197731 51197731 X 161006042 6060939 6060939 154945103 0 154945103 145239561 0 145239561 0 145239561 PART IV, LINE 1B: AGENT, TRUSTEE, CUSTODIAN, ETC. ARRANGEMENT THE COMMODITY FUTURES TRADING COMMISSION (CFTC) PERIODICALLY ASKS FEDERAL COURTS TO APPOINT NFA TO SERVE AS A COURT-APPOINTED MONITOR IN RESTITUTION JUDGMENTS AWARDED IN CFTC CASES BROUGHT BEFORE THE COURTS. AS MONITOR, NFA ASSISTS IN PROVIDING HARMED INVESTORS IDENTIFIED BY THE COURT ORDER WITH THEIR PRO-RATA SHARE OF RESTITUTION. THE RESTITUTION FUNDS ARE PLACED IN QUALIFIED SETTLEMENT FUNDS (QSF) WHICH ARE SEPARATE LEGAL ENTITIES ESTABLISHED AND TITLED PURSUANT TO A FEDERAL COURT ORDER. QSF ARE ORDINARILY SUBJECT TO THE CONTINUING JURISDICTION OF THE FEDERAL COURT. NFA HAS CHECK WRITING AUTHORITY FOR THE QSFS. PART X, LINE 2: LIABILITY FOR UNCERTAIN TAX POSITION (ASC 740) THE ASSOCIATION FOLLOWS GUIDANCE THAT CLARIFIES THE ACCOUNTING FOR UNCERTAINTY IN TAX POSITIONS TAKEN OR EXPECTED TO BE TAKEN IN A TAX RETURN, INCLUDING ISSUES RELATING TO FINANCIAL STATEMENT RECOGNITION AND MEASUREMENT. THIS GUIDANCE PROVIDES THAT THE TAX EFFECTS FROM AN UNCERTAIN TAX POSITION CAN ONLY BE RECOGNIZED IN THE FINANCIAL STATEMENTS IF THE POSITION IS MORE LIKELY THAN NOT TO BE SUSTAINED IF THE POSITION WERE TO BE CHALLENGED BY A TAXING AUTHORITY. THE ASSESSMENT OF THE TAX POSITION IS BASED SOLELY ON THE TECHNICAL MERITS OF THE POSITION, WITHOUT REGARD TO THE LIKELIHOOD THAT THE TAX POSITION MAY BE CHALLENGED. THE ASSOCIATION IS EXEMPT FROM FEDERAL INCOME TAX UNDER INTERNAL REVENUE CODE (IRC) SECTION 501(C)(6), THOUGH IT IS SUBJECT TO TAX ON INCOME UNRELATED TO ITS EXEMPT PURPOSE, UNLESS THAT INCOME IS OTHERWISE EXCLUDED BY THE CODE. THE ASSOCIATION HAS DETERMINED THAT THERE ARE NO MATERIAL UNCERTAIN TAX POSITIONS THAT REQUIRE RECOGNITION OR DISCLOSURE IN THE FINANCIAL STATEMENTS, AND THERE ARE NO INTEREST AND PENALTIES RECOGNIZED IN THE ACCOMPANYING FINANCIAL STATEMENTS. EAST ASIA AND THE PACIFIC 0 0 PROGRAM SERVICES EXAMINATIONS OF MEMBER FIRMS 96785 EUROPE (INCLUDING ICELAND & GREENLAND) 0 0 PROGRAM SERVICES EXAMINATIONS OF MEMBER FIRMS 189801 NORTH AMERICA 0 0 PROGRAM SERVICES EXAMINATIONS OF MEMBER FIRMS 50494 0 0 0 0 0 0 337080 0 337080 0 0 0 0 0 0 PART I, LINE 3: NFA USES THE ACCRUAL METHOD TO ACCOUNT FOR EXPENDITURES ON THE ORGANIZATION'S FINANCIAL STATEMENTS. ALL AMOUNTS REPORTED IN PART I, LINE 3, COLUMN (F) ARE EXPENDITURES FOR THE RESPECTIVE REGION(S). X 1 1 X X X 1 0 0 THOMAS SEXTON PRESIDENT AND CEO 877607 0 350000 0 10704 0 48300 0 33960 0 1320571 0 0 0 MICHAEL OTTEN SENIOR VICE PRESIDENT, OTC 618379 0 157500 0 8735 0 42183 0 33960 0 860757 0 0 0 CAROL WOODING SR.VP, GC, AND SECRETARY 611276 0 147500 0 10904 0 48300 0 30960 0 848940 0 0 0 REGINA THOELE SENIOR VICE PRESIDENT (THRU 2/2025) 631447 0 120000 0 10872 0 48300 0 34223 0 844842 0 0 0 TIMOTHY MCHENRY SENIOR VICE PRESIDENT 578762 0 147500 0 12633 0 48300 0 33960 0 821155 0 0 0 DAVID HAWRYSZ SR. VP, CFO, AND TREASURER 559494 0 110000 0 9428 0 48300 0 34463 0 761685 0 0 0 EDWARD DASSO SENIOR VICE PRESIDENT 573869 0 100000 0 8179 0 48300 0 5510 0 735858 0 0 0 KAREN WUERTZ SENIOR VICE PRESIDENT (THRU 2/2025) 465153 0 95000 0 12969 0 48300 0 30942 0 652364 0 0 0 LAUREN BRINATI VP, ADMIN STRATEGY RISK 452358 0 122500 0 6176 0 48300 0 14707 0 644041 0 0 0 DALE SPOLJARIC VICE PRESIDENT, OTC 411434 0 90000 0 4169 0 48300 0 30922 0 584825 0 0 0 NANCY C BOHANON VICE PRESIDENT, HR 323686 0 100000 0 7154 0 48300 0 29856 0 508996 0 0 0 ALESSANDRA RICCARDI MANAGING DIRECTOR, OTC 367607 0 36000 0 1510 0 37950 0 36317 0 479384 0 0 0 CLIFFE ALLEN MANAGING DIRECTOR, OTC 389507 0 36000 0 1482 0 31200 0 3669 0 461858 0 0 0 CYNTHIA IOANNACCI ASSOC. GENERAL COUNSEL 332752 0 32000 0 2795 0 26844 0 31889 0 426280 0 0 0 ANNE JOVES ASSOCIATE GENERAL COUNSEL 223721 0 0 0 171901 0 13266 0 2136 0 411024 0 0 0 YVETTE CHRISTMAN VICE PRESIDENT (THRU 2/2025) 279135 0 60000 0 2629 0 47100 0 14029 0 402893 0 0 0 JOSEPH HAWRYSZ MANAGING DIRECTOR, COMPLIANCE 163382 0 0 0 209304 0 10245 0 15601 0 398532 0 0 0 DANIEL DRISCOLL SPECIAL ADVISOR 251025 0 0 0 3073 0 35643 0 33320 0 323061 0 0 0 PART I, LINE 1A HEALTH OR SOCIAL CLUB DUES OR INITIATION FEES HEALTH CLUB DUES/EQUIPMENT PROVIDED TO OFFICERS THOMAS SEXTON, REGINA THOELE, KAREN WUERTZ, DAVID HAWRYSZ, EDWARD DASSO, AND MICHAEL OTTEN, IN THE AGGREGATE AMOUNT OF $11,111 REPORTED AS COMPENSATION ON FORM W2. NFA CURRENTLY DOES NOT OFFER FIRST CLASS OR BUSINESS CLASS TRAVEL ON DOMESTIC BUSINESS TRIPS, NFA OFFICERS MAY ELECT TO FLY PREMIUM ECONOMY WHEN TRAVELING OVERSEAS OR BUSINESS CLASS ON CERTAIN OVERSEAS DESTINATIONS. PART I, LINE 3 PROCESS FOR DETERMINING COMPENSATION THE COMPENSATION COMMITTEE IS COMPRISED OF THREE VOTING MEMBERS OF THE BOARD. FOR ALL OFFICERS EXCEPT THE CEO, THE CEO COLLABORATES WITH THE COMPENSATION COMMITTEE TO DETERMINE THE OFFICERS' COMPENSATION. ON AN ANNUAL BASIS, THE CEO AND THE COMPENSATION COMMITTEE DISCUSS EACH OFFICER'S CONTRIBUTION TO THE ORGANIZATION; THEY REVIEW COMPARABLE MARKET DATA PROVIDED BY NFA'S HUMAN RESOURCE DEPARTMENT AND DELIBERATE COMPENSATION RECOMMENDATIONS WHICH ARE DOCUMENTED AND PRESENTED TO THE EXECUTIVE COMMITTEE. THE SAME METHOD, AS DESCRIBED ABOVE, IS USED IN DETERMINING THE CEO'S COMPENSATION, ONLY THE CEO IS NOT PART OF THE PROCESS. THE EXECUTIVE COMMITTEE REVIEWS THE COMPENSATION COMMITTEE'S PROPOSED RECOMMENDATION AND EITHER ACCEPTS OR ADJUSTS THE PROPOSAL. THE EXECUTIVE COMMITTEE THEN MAKES ITS RECOMMENDATION TO THE BOARD OF DIRECTORS. THE BOARD OF DIRECTORS EITHER APPROVES OR MODIFIES THE EXECUTIVE COMMITTEE'S RECOMMENDATION. THE BOARD THEN APPROVES FINAL COMPENSATION FOR OFFICERS. THE ORGANIZATION CONTEMPORANEOUSLY DOCUMENTS AND MAINTAINS RECORDS OF DELIBERATIONS AND DECISIONS REGARDING THE COMPENSATION ARRANGEMENTS OF THE OFFICERS. JOSEPH HAWRYSZ BROTHER OF DAVID HAWRYSZ, AN OFFICER 372686 EMPLOYMENT 0 MARIA MCHENRY SPOUSE OF TIMOTHY MCHENRY, AN OFFICER 238422 EMPLOYMENT 0 DESI CHRISTMAN SISTER OF YVETTE CHRISTMAN, AN OFFICER 65391 EMPLOYMENT 0 SCH L, PART IV: THE INDIVIDUALS LISTED IN SCHEDULE L, PART IV EACH HAVE A FAMILIAL RELATIONSHIP WITH AN OFFICER OF THE FILING ORGANIZATION. THE RELATED OFFICERS HAVE NO DIRECT INVOLVEMENT IN THE DETERMINATION OF THEIR RELATIVES' COMPENSATION. ALL TRANSACTIONS ARE AT ARM'S LENGTH. FORM 990, PART VI, SECTION A, LINE 6 MEMBERS OR STOCKHOLDERS MEMBERS ARE DIVIDED INTO CATEGORIES BASED UPON THEIR REGISTRATION TYPE WITH THE COMMODITY FUTURES TRADING COMMISSION (CFTC). THE MEMBERSHIP CATEGORIES INCLUDE: CONTRACT MARKETS, FUTURES COMMISSION MERCHANTS AND LEVERAGED TRANSACTION MERCHANTS, INTRODUCING BROKERS, RETAIL FOREIGN EXCHANGE DEALERS, SWAP DEALERS, MAJOR SWAP PARTICIPANTS, COMMODITY POOL OPERATORS AND COMMODITY TRADING ADVISORS. MEMBERS ELECT REPRESENTATIVES FROM THEIR RESPECTIVE CATEGORIES TO THE BOARD OF DIRECTORS. THE BOARD OF DIRECTORS ELECTS PUBLIC DIRECTORS (NON-MEMBERS) TO THE BOARD OF DIRECTORS. OTHER THAN A CHANGE IN THE ARTICLES OF INCORPORATION, MEMBERS GENERALLY DO NOT APPROVE SIGNIFICANT DECISIONS OF THE GOVERNING BODY. UPON DISSOLUTION, THE NET ASSETS OF NFA, AFTER PAYMENT OF LIABILITIES, SHALL BE DISTRIBUTED TO THE MEMBERS IN PROPORTION TO THE DUES AND ASSESSMENTS PREVIOUSLY PAID. FORM 990, PART VI, SECTION A, LINE 7A MEMBERS OR STOCKHOLDERS WHO MAY ELECT A VACANCY ON THE BOARD THAT OCCURS BEFORE THE EXPIRATION OF A DIRECTOR'S TERM OR BECAUSE ADDITIONAL DIRECTORS IN EXISTING OR NEW MEMBER CATEGORIES ARE REQUIRED SHALL BE FILLED (FOR THE UNEXPIRED TERM) BY AN ELIGIBLE INDIVIDUAL ELECTED BY MAJORITY VOTE OF THE REMAINING DIRECTORS WHO REPRESENT THE CATEGORY OF MEMBERS IN WHICH THE VACANCY OCCURRED. SEE FORM 990, PART VI, LINE 6 ABOVE FOR THE NATURE OF THE VOTING RIGHTS FORM 990, PART VI, SECTION A, LINE 7B DECISIONS SUBJECT TO APPROVAL A CHANGE IN NFA'S ARTICLES OF INCORPORATION REQUIRES APPROVAL OF THE MAJORITY OF THOSE VOTING IN EACH MEMBERSHIP CATEGORY. FORM 990, PART VI, SECTION B, LINE 11B FORM 990 REVIEW PROCESS THE NFA TAX RETURNS ARE PREPARED BY A NATIONAL OUTSIDE PUBLIC ACCOUNTING FIRM. PRIOR TO FILING THE FORM 990 IT IS REVIEWED AND APPROVED BY NFA'S AUDIT COMMITTEE (THREE MEMBERS). THE REVIEW INVOLVES AN IN-DEPTH PRESENTATION BY NFA STAFF TO THE COMMITTEE. THE COMMITTEE WILL ALSO REVIEW THE OVERALL ACCURACY AND COMPLETENESS OF THE FORM 990. PRIOR TO FILING THE FORM 990, THE DRAFT RETURN IS PROVIDED TO THE REMAINING VOTING MEMBERS OF NFA'S GOVERNING BODY. NFA'S CFO ALSO REVIEWED THE 990 FOR OVERALL ACCURACY AND COMPLETENESS PRIOR TO FILING. FORM 990, PART VI, SECTION B, LINE 12C CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT AT NFA'S BOARD OF DIRECTORS' ANNUAL MEETING, NFA'S GENERAL COUNSEL AND CHIEF STRATEGY & RISK OFFICER PRESENTS, IN WRITING, NFA'S POLICY AND PROCEDURE ON CONFLICTS AND DUALITIES OF INTEREST ("POLICY"). EACH DIRECTOR IS SUBSEQUENTLY REQUIRED TO SIGN A WRITTEN STATEMENT THAT DISCLOSES ANY AFFILIATION THAT MAY GIVE RISE TO POTENTIAL CONFLICTS AND DUALITIES OF INTEREST UNDER THE POLICY. THE WRITTEN STATEMENT ALSO ACKNOWLEDGES THAT THE DIRECTOR HAS RECEIVED, READ AND UNDERSTOOD, AND AGREES TO ABIDE BY NFA'S POLICY; AND THAT THE DIRECTOR WILL DISCLOSE, AS IT OCCURS, ANY AFFILIATION THAT MAY GIVE RISE TO A CONFLICT OR DUALITY OF INTEREST UNDER THE POLICY. NFA'S GENERAL COUNSEL REVIEWS AND MAINTAINS THESE WRITTEN STATEMENTS AND CONSIDERS THEM AS MATTERS UPON WHICH THE BOARD ACTS ARISE. IF ANY DIRECTOR HAS AN AFFILIATION THAT MAY GIVE RISE TO A CONFLICT OR DUALITY OF INTEREST UNDER THE POLICY IN CONNECTION WITH A MATTER COMING BEFORE THE BOARD, NFA'S GENERAL COUNSEL BRINGS THE AFFILIATION TO THE BOARD'S ATTENTION IN THE EVENT THAT THE DIRECTOR DOES NOT. NFA'S STAFF IS REQUIRED TO ADHERE TO A CONFLICT OF INTEREST POLICY, WHICH IS MONITORED BY THE GENERAL COUNSEL AND CHIEF STRATEGY AND RISK OFFICER. STAFF SEMIANNUALLY COMPLETE THEIR CONFLICT OF INTEREST QUESTIONNAIRES, WHICH HUMAN RESOURCES REVIEWS AND MAINTAINS. IF ANY CONFLICTS ARISE, THE GENERAL COUNSEL OR CHIEF STRATEGY AND RISK OFFICER DISCUSSES THE POTENTIAL CONFLICT WITH THE STAFF MEMBER, AND DOCUMENTS ACTIONS TAKEN; WHETHER DISPOSAL OF THE INTEREST OR ANY DISCIPLINARY ACTION UNDER THE CODE OF PROFESSIONAL CONDUCT IS WARRANTED DEPENDS ON THE LEVEL OF CONFLICT UNDER REVIEW. FORM 990, PART VI, SECTION B, LINE 15 PROCESS FOR DETERMINING COMPENSATION THE COMPENSATION COMMITTEE IS COMPRISED OF THREE VOTING MEMBERS OF THE BOARD. FOR ALL OFFICERS EXCEPT THE CEO, THE CEO COLLABORATES WITH THE COMPENSATION COMMITTEE TO DETERMINE THE OFFICERS' COMPENSATION. ON AN ANNUAL BASIS, THE CEO AND THE COMPENSATION COMMITTEE DISCUSS EACH OFFICER'S CONTRIBUTION TO THE ORGANIZATION; THEY REVIEW COMPARABLE MARKET DATA PROVIDED BY NFA'S HUMAN RESOURCE DEPARTMENT AND DELIBERATE COMPENSATION RECOMMENDATIONS WHICH ARE DOCUMENTED AND PRESENTED TO THE EXECUTIVE COMMITTEE. THE SAME METHOD, AS DESCRIBED ABOVE, IS USED IN DETERMINING THE CEO'S COMPENSATION, ONLY THE CEO IS NOT PART OF THE PROCESS. THE COMPENSATION COMMITTEE PROVIDES THE BOARD OF DIRECTORS WITH ITS PROPOSED RECOMMENDATION FOR NFA'S OFFICERS' COMPENSATION AND THE BOARD MAY ACCEPT OR MODIFY THE COMMITTEE'S RECOMMENDATION. THE BOARD THEN APPROVES THE FINAL COMPENSATION FOR NFA'S OFFICERS. THE ORGANIZATION CONTEMPORANEOUSLY DOCUMENTS AND MAINTAINS RECORDS OF DELIBERATIONS AND DECISIONS REGARDING THE COMPENSATION ARRANGEMENTS OF THE OFFICERS. FORM 990, PART VI, SECTION C, LINE 19 HOW DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC THE ORGANIZATION MAKES ITS BYLAWS, ARTICLES OF INCORPORATION AND FINANCIAL STATEMENTS AVAILABLE ON ITS WEBSITE OR UPON WRITTEN REQUEST. THE CONFLICTS OF INTEREST POLICY IS AVAILABLE UPON REQUEST. FORM 990, PART XI, LINE 9: NET PERIODIC BENEFIT COSTS -350,489.