CSI offers a wide range of services to its individual and business clients. Listed below are the services we offer to our clients along with a brief description. Please note that the list is not necessarily all-inclusive. Therefore, please feel free to inquire about a particular service if you do not see it listed.
- ”On-siteOpen or Close
CSI conducts customized on-site inspections for FCMs, IBs, CPOs, and CTAs to ensure current rules and regulations are being adhered to on a consistent basis. Although many of our clients view this service as simply a “Mock NFA Audit”, we go the extra step and assist you in correcting any problem areas. We follow a proprietary on-site inspection program that has been designed to address all areas of your business. We have trained and experienced staff conducting the inspections. During these inspections, we interview key personnel, review books and records required to be prepared and maintained during the normal course of business, and review for compliance with rules and regulations of the industry.
- ”FinancialOpen or Close
We are committed to providing our clients with the required financial information in a timely and accurate manner. Having meaningful and well organized financial records results in you running your business more efficiently and with very little or no hassles during a regulatory audit. We provide a full range of cost effective accounting services that we customize to your business needs.
- ”CertifiedOpen or Close
Through an affiliated entity, we offer CPA services to those entities (i.e., FCMs, independent IBs, commodity pools) required to file certified financial statements. New introducing brokers, who choose not to operate pursuant to a guarantee agreement with an FCM, could file a certified financial statement to become registered with the CFTC. Through the affiliated entity, we can offer new IBs an opportunity to have their financial statements certified while CSI assists in other compliance matters for the firm.
- ”ComplianceOpen or Close
As part of your business, you are required to establish and enforce written compliance policies and procedures. The type of written policies and procedures varies from firm to firm depending on the type of business being transacted, the type of registration being held, and the backgrounds of the registered associated persons. Through a detailed interview process, CSI can write and customize your written policies and procedures manual. If your firm currently has a policy and procedures manual in force, we can review the manual to ensure it meets the current requirements and fits your business needs. What is important to know is that we do not boiler plate your manual as we stand committed to ensuring that the manual fits your business.
- ”TrainOpen or Close
The rules and regulations governing your operations are often complex and constantly changing. If your firm, whether small or large, does not possess the right amount of resources to keep on top of the changes that affect your business, we can provide your organization with the necessary amount of training. The training could be either on-site or through routine electronic mail notices explaining what the new or changed requirements are, what your staff needs to know, and how to ensure compliance.
- ”PayrollOpen or Close
As a business grows, it generally hires more employees. This results in increased payroll administration that can often prove to be burdensome to a small company that is not proficient with federal and state tax laws. We can assist you in implementing the controls necessary to ensure a reliable, efficient, and effective payroll system. Our firm can also calculate payroll and prepare all necessary payroll tax returns in a timely manner. CSI compiles federal and state business tax returns for partnerships (commodity pools) and corporations (C-Corporations and S-Corporations).
- ”ReviewOpen or Close
If your company uses promotional material (whether prepared internally or by a third party), your company is required to adhere to the regulatory agencies promotional material requirements. This area is heavily reviewed by the regulatory agencies and is generally the largest problematic area during audits. We cannot over-emphasize the importance of ensuring that all promotional material used by your company is in full compliance. Therefore, we provide a full and complete review of your promotional material and provide options on how to correct any potential problems. Our services cover promotional materials such as websites, e-mail communications, radio and television advertisements, sales scripts, and all hard copy communications to your existing and prospective customers.
- ”EstablishOpen or Close
Choosing the form of entity for your new business (e.g. “S” corporation, sole proprietorship, limited liability company, etc.) could prove to be a crucial decision that can have certain tax implications. Our company can help you evaluate the pros and cons of each entity type to help you determine the most advantageous form of business for your company.CSI can organize your company with the state regulatory authorities and file for the necessary tax identification numbers. CSI also ensures that your corporate book contains the information required by NFA and the CFTC. Furthermore, we can take you from an idea that you have created to registration and membership in a relatively short period of time.
By using our services in this area, you can expect to decrease the amount of time it takes for the registration and membership process and have CSI manage all membership problems to permit you to focus on getting your business up and running. We have found that a big part of our service is assisting individuals in determining if CFTC registration and NFA membership is required and what type of registration exemptions may be available.
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Specific services for:
Futures Commission Merchants and Introducing Brokers
Futures Commission Merchants (“FCM”) and independent introducing brokers (“IB”) are required to maintain accounting records in accordance with generally accepted accounting principles. In order to comply with CFTC regulations and NFA Rules, FCMs and independent IBs must compute adjusted net capital following many involved and to a certain degree, complex rules and regulations.
In addition to the services outlined under “General Services”, CSI offers the following services to FCMs and independent IBs:
- ”CompilationOpen or Close
We can assist you in the preparation and compilation of your financial statements and net capital computations in accordance with professional standards, generally accepted accounting principals, and current rules and regulations enforced by the CFTC, NFA, NASD, and the SEC. It should be noted that for monthly, quarterly, and semi-annual unaudited financial statements, we do not express opinions or any other form of assurance.
- ”FilingOpen or Close
NFA’s Financial Requirements require that FCMs and IBs file all un-audited financial statements and net capital computations using the WinJammerTM electronic filing system. We possess the necessary software and systems to file the required information to these regulatory agencies on your behalf.
- ”IndependentOpen or Close
CSI conducts independent audits on FCM and IB anti-money laundering (“AML”) compliance programs as required by NFA Compliance Rule 2-9. These audits are designed to ensure the firm’s AML compliance program is adequate to prevent and detect money laundering activity. In addition, CSI’s audit will determine whether or not the firm is adhering to its AML policy on a consistent basis. CSI follows a proprietary AML audit program that has been designed to address all pertinent areas of the Patriot Act. Trained and experienced staff conducts these audits.
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Commodity Trading Advisors, Commodity Pool Operators, and Investment Advisers
Like FCMs and independent IBs, commodity pool operators (“CPO”) are required to maintain accounting systems and prepare periodic financial statements for each pool they operate. CPOs are required to distribute account statements to pool participants. In addition, CPOs are required to distribute an Annual Report to each pool participant and to NFA and the CFTC each year.
Every registered CPO and CTA must supply prospective participants and clients with a Disclosure Document. This document is intended to provide information to participants and clients that they will need to make informed investment decisions. The regulations are specific in terms of when the Disclosure Document must be provided and what information has to be included.
In addition to the services outlined under “General Services”, CSI offers the following services to CPOs and CTAs:
- ”OrganizeOpen or Close
CSI will work with you to form a new entity that will serve as the commodity pool or fund. These services include, but are not limited to, organizing the commodity pool in the state of your choice, filing for federal and state tax identification numbers, and filing the necessary forms with the SEC and the state securities regulators pursuant to the Blue Sky requirements. The latter service is performed in conjunction with an attorney.
- ”PrepareOpen or Close
Having a proper disclosure document in place is paramount to your business in many respects. Each and every disclosure document prepared by CSI is done so with a very high level of detail. We strive to obtain as much information about your business, the people behind the business, strategies, business relationships and the overall operations through a rigorous interview and questionnaire process. Our disclosure documents are truly customized to your business with the rules and regulations in mind.
- ”FilingOpen or Close
After preparing the disclosure document and upon your review and approval, we will file the disclosure document(s) with the regulatory agencies. Additionally, if the regulatory agencies have questions, we follow-up with them. This will leave you time to concentrate on what should be important to you – servicing your clients with the utmost care and attention.
- ”FundOpen or Close
We prepare and compile financial statements for Funds in accordance with professional standards, generally accepted accounting principles, and current rules and regulations enforced by the CFTC and NFA. We handle subscription and redemption proceeds for the Fund in a tightly controlled environment in an authorized Fund bank account at an bank and administer compliance for subscriptions in order to keep the administration out of the hands of the Fund’s operator. We handle the quarterly filing requirements for pool operators with the applicable regulatory authorities. It should be noted that for monthly, quarterly, and semi-annual un-audited financial statements, we do not express opinions as administrators or any other form of assurance on the underlying information included in them. Furthermore, our services include computing the management and/or incentive fees due to the commodity pool operator(s) and commodity trading advisor(s), and if applicable, any trading managers involved with the commodity pool. We compile Year End Federal and State (if applicable) tax returns and investor K-1s. We assist with year-end certified audits performed by an independent certified public accountant by being available for questions and providing the necessary records.
- ”CompilingOpen or Close
Having a disclosure document and a good trading program is one thing, but there is no other way to offer your services unless you have a meaningful performance track record. We compile track records (i.e., performance tables and performance capsules) for each trading program offered by your company and compute management and/or incentive fees in accordance with generally accepted accounting principles and current rules and regulations. We take pride and work hard in providing you with the trading results soon after the end of the month. Furthermore, our reports are meaningful, all inclusive, and transmitted to you electronically so you can easily forward the information to your clients and other companies who are interested in seeing this information.
- ”ExemptOpen or Close
Through discussions with you about your business plans and objections, we may determine that you and the commodity pool you plan to offer may qualify for exempt status. Although not as involved as a regulated commodity pool, your company will still be bound by certain rules and regulations. We can assist your company in achieving and maintaining the exempt status and compiling required financial reports for your commodity pool participants.
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For a sample look at the monthly reports we can provide to your company for each commodity pool, click here:Sample Commodity Pool Reports.
For a sample look at the monthly reports we can provide to CTAs, click here: Sample Trading Program Reports.
In addition to the services outlined under “General Services”, CSI offers the following services to Investment Advisers:
- ”AIMR-PPSOpen or Close
For firms wishing to attain compliance with AIMR Performance Standards, firms often need help attaining compliance before they are ready for verification. CSI understands this need and encourages firms to take advantage of its knowledge base on the front end of the compliance process. Additionally, CSI can consult with the firm during the verification. Furthermore, CSI can assist the firm in developing efficient processes with regards to calculations, presentations and record keeping.
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