Quick Answer
A Futures Commission Merchant files unaudited financial reports monthly; an independent Introducing Broker files them semiannually. Both also file an annual certified (audited) report, the FCM within 60 days of its fiscal year-end and the independent IB within 90 days. A guaranteed IB files none, excused by its guarantee agreement.
Financial reporting tracks net-capital responsibility, so this section follows directly from the last one: the firms that keep their own capital are the firms that file their own reports.
Who Files, and How Often
The reporting cadence mirrors how much customer risk each firm carries.
- A Futures Commission Merchant (FCM) files periodic unaudited financial reports on a monthly basis with the Commodity Futures Trading Commission (CFTC) and its self-regulatory organization, the National Futures Association (NFA). Monthly filing reflects its ongoing duty as a custodian of customer funds.
- An independent Introducing Broker (IB) files periodic unaudited financial reports less frequently, on a semiannual basis, consistent with its lighter role.
- Both the FCM and the independent IB must also file an annual certified (audited) financial report, prepared by an independent public accountant.
The Annual Audited-Report Deadlines
The two deadlines are a favorite exam detail, and they are not the same.
| Firm | Annual audited report due |
|---|---|
| Futures Commission Merchant (FCM) | Within 60 days of fiscal year-end |
| Independent Introducing Broker (IB) | Within 90 days of fiscal year-end |
- The FCM gets the tighter deadline, 60 days, because it holds customer money and regulators want its certified numbers sooner.
- The independent IB files its audited report within 90 days of its fiscal year-end.
Exam Tip: Gotchas
- FCM audited report = 60 days; independent IB audited report = 90 days. The trap swaps the two deadlines. The firm holding customer funds (the FCM) has the shorter window.
Guaranteed IBs Are Excused
The pattern from the capital section repeats: no separate capital duty means no separate reporting duty.
- A guaranteed IB files none of these standalone financial reports. The guarantee agreement with its FCM stands in for both the minimum-capital and the financial-reporting requirements, and the guarantor FCM's own reporting covers the relationship.
Exam Tip: Gotchas
- Financial reporting tracks net-capital responsibility. If a firm has no separate capital minimum (the guaranteed IB), it has no separate reporting duty either. An answer that makes a guaranteed IB file its own reports is wrong.