2018-11-09T10:33:45-06:00 2018-06-30 GRANT THORNTON LLP 171 N CLARK ST SUITE 200 CHICAGO IL 60601 990 2017-07-01 362960981 National Futures Association % DAVID HAWRYSZ NATI 3127811300 300 S RIVERSIDE PLAZA Suite 1800 CHICAGO IL 606066615 DAVID HAWRYSZ Sr VP, CFO,Treasurer 3127811300 2018-11-09 true Bridget T Roche P00666837 3128560200 209.220.64.52 36941220183135000000 2018-11-09 P 6FF173CE78174BB3A836CA1CE10F2B519AECB234 8570B2D8046878F456576E706BB8FB99030C32C0 2017 2019-02-21 02:37:17Z NFA David Hawrysz 300 S RIVERSIDE PLAZA STE 1800 CHICAGO IL 60606 95814953 false X www.nfa.futures.org X 1976 DE NFA IS A SELF-REGULATORY MEMBERSHIP ORGANIZATION FORMED TO MONITOR AND MAINTAIN THE INTEGRITY OF THE DERIVATIVES TRADING INDUSTRY. 29 29 600 0 0 60834 0 0 80509339 94624323 947012 1190630 0 0 81456351 95814953 0 0 0 0 68176255 74600811 0 0 0 23659656 23556551 91835911 98157362 -10379560 -2342409 125595122 127573941 22400491 25574280 103194631 101999661 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 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. false false 0 0 0 NFA IS THE INDUSTRYWIDE SELF-REGULATORY ORGANIZATION FOR THE U.S. DERIVATIVES INDUSTRY. DESIGNATED BY THE CFTC AS A REGISTERED FUTURES ASSOCIATION, NFA STRIVES TO SAFEGUARD THE INTEGRITY OF THE DERIVATIVES MARKETS, PROTECT INVESTORS AND ENSURE THAT NFA MEMBERS MEET THEIR REGULATORY RESPONSIBILITIES. ENFORCEMENT ACTIONS ENFORCEMENT OF NFA RULES IS CRITICAL TO THE EFFECTIVENESS OF THE SELF-REGULATORY PROCESS. IN FY 2018: * NFAS BUSINESS CONDUCT COMMITTEE ISSUED 17 COMPLAINTS AGAINST 27 RESPONDENTS. A NUMBER OF THESE CASES INVOLVED MEMBERS AND ASSOCIATES WHO FAILED TO SUPERVISE, COOPERATE WITH NFA OR OBSERVE HIGH STANDARDS OF COMMERCIAL HONOR AND JUST AND EQUITABLE PRINCIPLES OF TRADE. * NFAS DISCIPLINARY PANELS ISSUED 16 DECISIONS, AND ORDERED 6 EXPULSIONS AND 5 SUSPENSIONS. * NFA COLLECTED NEARLY $550,000 IN FINES. MANY OF THESE CASES WERE THE CULMINATION OF COMPLEX AND EXHAUSTIVE INVESTIGATIONS THAT SPANNED MULTIPLE YEARS AND INVOLVED COLLABORATION WITH THE CFTC AND OTHER REGULATORS. NFA REGULARLY MEETS WITH THE U.S. DEPARTMENT OF JUSTICE'S SECURITIES AND COMMODITIES FRAUD WORKING GROUP, THE U.S. ATTORNEY'S OFFICE, THE FEDERAL BUREAU OF INVESTIGATION, THE U.S. POSTAL INSPECTOR'S OFFICE, THE CFTC, AND THE ILLINOIS DEPARTMENT OF SECURITIES. OVER THE LAST SEVERAL YEARS, NFA'S WORK WITH THESE AGENCIES HAS RESULTED IN SIGNIFICANT PRISON SENTENCES FOR NEARLY 30 INDIVIDUALS, INCLUDING SENTENCES OF MORE THAN 20 YEARS. REGISTRATION NFA SCREENS ALL FIRMS AND INDIVIDUALS WISHING TO REGISTER WITH THE CFTC AND BECOME NFA MEMBERS. IN FY 2018, NFA'S REGISTRATION DEPARTMENT PROCESSED NEARLY 500 FIRM REGISTRATIONS AND APPROXIMATELY 8,400 INDIVIDUAL REGISTRATIONS. INFORMATION CENTER NFA'S INFORMATION CENTER - A SERVICE NFA OFFERS TO MEMBERS AND THE INVESTING PUBLIC - RECEIVED MORE THAN 24,000 CALLS AND RESPONDED TO OVER 3,000 EMAILS. FITNESS INVESTIGATION CASES NFA'S FITNESS INVESTIGATIONS GROUP OPENED APPROXIMATELY 1,300 CASES. THESE FITNESS INVESTIGATION CASES ARE DUE TO FINGERPRINT CARD RESULTS, ANSWERS TO A DISCIPLINARY HISTORY QUESTION ON THE APPLICATION, OR REGULATORY INFORMATION OBTAINED DURING NFA'S BACKGROUND CHECKS. RESTITUTION NFA'S RESTITUTION PROGRAM HELPS RETURN PROCEEDS OF FRAUDULENT SCHEMES TO HARMED INVESTORS. THE MAJORITY OF THESE CASES DO NOT INVOLVE NFA MEMBERS. IN FY 2018, NFA'S RESTITUTION PROGRAM DISBURSED MORE THAN $10 MILLION TO NEARLY 2,500 HARMED INVESTORS. BECAUSE NFA DOES NOT CHARGE FEES FOR ADMINISTERING THIS RESTITUTION SERVICE, FRAUD VICTIMS ARE RETURNED THE MAXIMUM AMOUNT OF MONEY POSSIBLE. OVER THE LIFE OF THE RESTITUTION PROGRAM, NFA HAS DISTRIBUTED MORE THAN $45 MILLION TO APPROXIMATELY 15,500 INDIVIDUALS. NFA MEMBERSHIP AS OF JUNE 30, 2018, NFA HAD APPROXIMATELY 3,700 MEMBERS AND NEARLY 50,000 ASSOCIATE MEMBERS. 0 false false false true false false false true false true false false false true true true false false false true false false false false false false false false true false false false false false false false false false false false false false false true 84 0 true 600 true true true false false false false false X 29 29 false false false false true true true true true false false true true true true true true true true false CA X DAVID HAWRYSZ 3127811300 300 SOUTH RIVERSIDE PLAZA SUITE 18 Chicago IL 60606 X Paul Georgy Board Member - Thru 2/2018 1.0 0.0 X 8000 0 0 Douglas Bry Board Member 1.0 0.0 X 16000 0 0 Ernest Jaffarian Board Member 1.0 0.0 X 16000 0 0 Gerald Corcoran Board Member 1.0 0.0 X 16000 0 0 Michael Dawley Chairman 1.0 0.0 X 16000 0 0 Maureen Downs Vice Chair 1.0 0.0 X 16000 0 0 Ronald Filler Board Member 1.0 0.0 X 42400 0 0 Douglas Harris Board Member 1.0 0.0 X 38500 0 0 Jim Marshall Board Member 1.0 0.0 X 21500 0 0 Michael Moskow Board Member 1.0 0.0 X 41500 0 0 Charles Nastro Board Member 1.0 0.0 X 25500 0 0 Ronald Oppenheimer Board Member 1.0 0.0 X 42000 0 0 Todd Petzel Board Member 1.0 0.0 X 40000 0 0 Mark Bagan Board Member 1.0 0.0 X 8000 0 0 David Goone Board Member 1.0 0.0 X 18000 0 0 John Sandner Board Member 1.0 0.0 X 14000 0 0 Antonio Reyes Miras Board Member 1.0 0.0 X 8000 0 0 Michael Burke Board Member 1.0 0.0 X 8000 0 0 Brendan Kalb Board Member - Thru 2/2018 1.0 0.0 X 8000 0 0 Mary McDonnell Board Member 1.0 0.0 X 20000 0 0 Philip Olesen Board Member 1.0 0.0 X 0 0 0 Charlotte McLaughlin Board Member 1.0 0.0 X 0 0 0 Don Thompson Board Member 1.0 0.0 X 16000 0 0 Andrea Corcoran Board Member - Thru 2/2018 1.0 0.0 X 20000 0 0 Michael Schaefer Board Member 1.0 0.0 X 21500 0 0 Sheryl Wallace Board Member 1.0 0.0 X 0 0 0 Thomas Kadlec Board Member 1.0 0.0 X 8000 0 0 William McCoy Board Member 1.0 0.0 X 0 0 0 Martin Lueck Board Member 1.0 0.0 X 8000 0 0 Nicola Watson Board Member - As of 2/2018 1.0 0.0 X 0 0 0 Scott Stewart Board Member - As of 2/2018 1.0 0.0 X 0 0 0 Arthur Hahn Board Member - As of 2/2018 1.0 0.0 X 0 0 0 Thomas Sexton President and CEO 40.0 0.0 X 702713 0 60310 Daniel Driscoll Vice President and COO 40.0 0.0 X 613663 0 60232 Regina Thoele Senior VP 40.0 0.0 X 547532 0 59658 Karen Wuertz Senior VP 40.0 0.0 X 406166 0 59178 David Hawrysz Sr. VP, CFO, and Treasurer 40.0 0.0 X 437464 0 60495 Edward Dasso Vice President 40.0 0.0 X 496673 0 66721 Jamila Piracci Vice President 40.0 0.0 X 508184 0 57614 Yvette Christman Vice President 40.0 0.0 X 211095 0 40691 Timothy McHenry Vice President 40.0 0.0 X 385876 0 65564 Carol Wooding VP, GC, and Secretary 40.0 0.0 X 375661 0 57552 Daniel Roth Special Advisor to Pres 2.0 0.0 X 346266 0 42102 Michael Crowley Associate General Counsel 40.0 0.0 X 294385 0 44089 Thomas Gisonda Managing Dir, OTC Derivatives 40.0 0.0 X 293185 0 44057 Michael Abramowitz Managing Director, Market Reg 40.0 0.0 X 275466 0 22947 Dale Spoljaric Managing Director, Compliance 40.0 0.0 X 275155 0 51576 6666384 0 792786 198 false true false CDW Direct LLC PO Box 75723 CHICAGO IL 606755723 computer support 1272539 Destiny Corporation 2075 Silas Deane Highway ROCKY HILL CT 060672338 Bus & Tech Consultng 1014158 Redlegg PO Box 5998 CAROL STREAM IL 601975998 SOFTWARE SUPPORT 439089 Dell Marketing LP PO Box 802816 CHICAGO IL 60680 computer support 420671 Jenner Block 353 N Clark Street CHICAGO IL 60654 legal consulting 389385 29 0 ASSESSMENT FEES & MARKET SERVICE REV 900099 53555185 53555185 MEMBERSHIP DUES 900099 38923919 38923919 REGISTRATION & TESTING FEES 900099 1230456 1230456 REGULATORY FINES 900099 575000 575000 ARBITRATION REVENUE 900099 73204 73204 266559 266559 94624323 1190630 1190630 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 95814953 94624323 1190630 0 0 0 0 5759590 0 52341170 5214009 7157608 4128434 0 457064 18042 0 0 0 1913569 25250 969680 2943903 0 3799600 4003643 0 259262 0 0 7503693 0 EDUCATION AND RECRUITMENT 1366910 DUES AND SUBSCRIPTION 295935 98157362 22402169 8457144 14990625 27998222 0 0 1293910 1309709 0 0 0 0 0 0 0 0 1134795 1563929 34332691 20243902 16289625 14088789 66898534 69289780 0 0 0 0 0 0 2585464 4866368 125595122 127573941 3836358 5337296 0 0 9183112 9858718 0 0 0 0 0 0 0 0 0 0 9381021 10378266 22400491 25574280 X 103194631 101999661 0 0 0 0 103194631 101999661 125595122 127573941 -2342409 1147439 X false true X true false false false false 92479104 21441 21441 21441 true 12791970 1822186 8807779 5806377 false 11736702 6799573 4937129 8783219 4896755 3886464 13812770 8547574 5265196 14088789 0 POST RETIREMENT 9355423 UNCLAIMED DISBURSEMENT 76331 ALL OTHER LIABILITIES 946512 10378266 X 96962392 1147439 1147439 95814953 95814953 98157362 98157362 98157362 AGENT, TRUSTEE, CUSTODIAN, ETC. ARRANGEMENT SCHEDULE D, PART IV, LINE 1B THE COMMODITY FUTURES TRADING COMMISSION (CFTC) PERIODICALLY ASKS FEDERAL COURTS TO APPOINT NFA TO SERVE AS COURT-APPOINTED MONITOR IN RESTITUTION JUDGMENTS AWARDED IN CFTC CASES BROUGHT BEFORE THE COURTS. AS MONITOR, NFA ENSURES HARMED INVESTORS IDENTIFIED BY THE COURT ORDER RECEIVE 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 BODY. NFA HAS CHECK WRITING AUTHORITY FOR THE QSFS. LIABILITY FOR UNCERTAIN TAX POSITION (ASC 740) SCHEDULE D, PART X, LINE 2 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 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. false North America 31 Program Services Audit of Member Firms 148099 Europe (Including Iceland and Greenland) 30 Program Services Audit of Member Firms 304230 East Asia and The Pacific 9 Program Services Audit of Member Firms 122054 70 70 574383 574383 false false false false false false METHOD USED TO ACCOUNT FOR EXPENDITURES SCHEDULE F, PART I, LINE 3, COLUMN (F) THE TOTAL PROGRAM SERVICE EXPENDITURES IN NORTH AMERICA, EUROPE, AND ASIA HAVE BEEN REPORTED USING THE ACCRUAL METHOD OF ACCOUNTING, THE SAME METHOD USED FOR NFA'S AUDITED FINANCIAL STATEMENTS. X true true X X X false false false Thomas Sexton President and CEO 626519 0 75000 0 1194 0 37800 0 22510 0 763023 0 0 0 Daniel Driscoll Vice President and COO 555555 0 55000 0 3108 0 37800 0 22432 0 673895 0 0 0 Regina Thoele Senior VP 488946 0 55000 0 3586 0 37800 0 21858 0 607190 0 0 0 Karen Wuertz Senior VP 357960 0 45000 0 3206 0 37800 0 21378 0 465344 0 0 0 David Hawrysz Sr. VP, CFO, and Treasurer 389974 0 45000 0 2490 0 37800 0 22695 0 497959 0 0 0 Edward Dasso Vice President 449024 0 45000 0 2649 0 37800 0 28921 0 563394 0 0 0 Jamila Piracci Vice President 457142 0 50000 0 1042 0 37800 0 19814 0 565798 0 0 0 Yvette Christman Vice President 185519 0 25000 0 576 0 30041 0 10650 0 251786 0 0 0 Timothy McHenry Vice President 323233 0 60000 0 2643 0 43800 0 21764 0 451440 0 0 0 Carol Wooding VP, GC, and Secretary 323835 0 47500 0 4326 0 37800 0 19752 0 433213 0 0 0 Daniel Roth Special Advisor to Pres 345786 0 0 0 480 0 34125 0 7977 0 388368 0 0 0 Michael Crowley Associate General Counsel 261706 0 32100 0 579 0 24141 0 19948 0 338474 0 0 0 Thomas Gisonda Managing Dir, OTC Derivatives 265940 0 25000 0 2245 0 24310 0 19747 0 337242 0 0 0 Michael Abramowitz Managing Director, Market Reg 249746 0 25000 0 720 0 22825 0 122 0 298413 0 0 0 Dale Spoljaric Managing Director, Compliance 259861 0 14500 0 794 0 30330 0 21246 0 326731 0 0 0 HEALTH OR SOCIAL CLUB DUES OR INITIATION FEES SCHEDULE J, PART I, LINE 1A HEALTH CLUB DUES PROVIDED TO CAROL WOODING, DANIEL DRISCOLL, DANIEL ROTH, REGINA THOELE, KAREN WUERTZ, TIM MCHENRY, DAVID HAWRYSZ, EDWARD DASSO, JAMILA PIRACCI AND THOMAS SEXTON, STAFF AND OFFICERS, IN THE AMOUNT OF $13,406 WAS REPORTED AS COMPENSATION ON FORM W-2. NFA CURRENTLY DOES NOT OFFER FIRST CLASS TRAVEL. ON OVERSEAS BUSINESS TRIPS, NFA OFFICERS MAY ELECT TO FLY BUSINESS CLASS. MEMBERS OR STOCKHOLDERS FORM 990, PART VI, SECTION A, LINE 6 MEMBERS ARE DIVIDED INTO CATEGORIES BASED UPON THE CATEGORIES THEY ARE REGISTERED WITH THE COMMODITY FUTURES TRADING COMMISSION ("CFTC"). THE MEMBERSHIP CATEGORIES INCLUDE: CONTRACT MARKETS, FUTURE 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. MEMBERS OR STOCKHOLDERS WHO MAY ELECT FORM 990, PART VI, SECTION A, LINE 7A 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. DECISIONS SUBJECT TO APPROVAL FORM 990, PART VI, SECTION A, LINE 7B A CHANGE IN NFA'S ARTICLES OF INCORPORATION REQUIRES APPROVAL OF THE MAJORITY OF THOSE VOTING IN EACH MEMBERSHIP CATEGORY. FORM 990 REVIEW PROCESS FORM 990, PART VI, SECTION B, LINE 11B 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 WAS PROVIDED TO THE REMAINING VOTING MEMBERS OF NFA'S GOVERNING BODY. NFA'S COO ALSO REVIEWED THE 990 FOR OVERALL ACCURACY AND COMPLETENESS PRIOR TO FILING. CONFLICT OF INTEREST POLICY MONITORING & ENFORCEMENT FORM 990, PART VI, SECTION B, LINE 12C AT NFA'S BOARD OF DIRECTORS ANNUAL MEETING, NFA'S GENERAL COUNSEL 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 LISTS 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 REFERS TO 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 HUMAN RESOURCES. STAFF ANNUALLY COMPLETE THEIR CONFLICT OF INTEREST QUESTIONNAIRES, WHICH HUMAN RESOURCES REVIEWS AND MAINTAINS. IF ANY CONFLICTS ARISE, THE GENERAL COUNSEL 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. PROCESS FOR DETERMINING COMPENSATION FORM 990, PART VI, SECTION B, LINES 15A AND 15B 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 REMAINING OFFICERS' COMPENSATION. 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 THEIR 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 RECORDKEEPING FOR DELIBERATIONS AND DECISIONS REGARDING THE COMPENSATION ARRANGEMENTS OF THE OFFICERS. HOW DOCUMENTS ARE MADE AVAILABLE TO THE PUBLIC FORM 990, PART VI, SECTION C, LINE 19 THE ORGANIZATION MAKES ITS BYLAWS, ARTICLES OF INCORPORATION AND FINANCIAL STATEMENTS AVAILABLE ON ITS WEBSITE OR UPON WRITTEN REQUEST. CONFLICTS OF INTEREST POLICY IS AVAILABLE UPON REQUEST. SPECIAL ADVISOR TO THE BOARD FORM 990, PART VII NFA'S BOARD HAS APPOINTED A PERMANENT SPECIAL ADVISOR TO THE EXECUTIVE COMMITTEE AND THE BOARD OF DIRECTORS. THE PERSON HOLDING THIS ROLE RECEIVES A STIPEND FOR ATTENDING MEETINGS SIMILAR TO THAT OF MEMBERS OF THE BOARD.