Beginning with statements for the period ended June 30, 2003, NFA imposed a rule that results in a late filing fee of $200 for each business day the financial statement is late (NFA Financial Requirements, Section 10).
http://www.nfa.futures.org/nfaManual/entireManual.asp#fins10

Additionally, beginning July 1, 2004, NFA began offering its EasyFile system for IBs to submit form 1-FR-IB. NFA intends to expand EasyFile in the futures, making it available to all Members with financial reporting requirements. http://www.nfa.futures.org/compliance/070104.asp

To help our Member FCMs and IBs use the WinJammer^TM system more efficiently, we have developed the following Frequently Asked Questions document. If you have additional questions or concerns, please contact Brian Rothfuss at (312) 781-1439 or brothfuss@nfa.futures.org.

1. My firm is applying for CFTC registration and NFA Membership. Is the initial applicant financial statement required to be submitted electronically via WinJammer^TM?
2. My firm needs to sign-up for a WinJammer^TM PIN. What do I do?
3. Who qualifies as an approved PIN signer for my firm?
4. My firm's PIN signer is no longer employed with my firm. What should I do?
5. I submitted a WinJammer^TM PIN agreement, what's next?
6. I submitted a WinJammer^TM PIN agreement form but have not received any further information. Why?
7. The WinJammer^TM PIN file(s) e-mailed to me have been blocked by my e-mail software. Who can I contact for help?
8. I am experiencing difficulties installing the WinJammer^TM software. Who can I contact for assistance?
9. I have installed the WinJammer^TM software on my computer. What's next?
10. How do I complete a statement in WinJammer^TM (the software's installed, the firm information is set-up and the PIN file(s) are imported)?
11. How do I save the work I have done on my statement and work on it later?
12. Based on the number of associated persons ("APs") and branch offices ("BOs"), my firm's minimum net capital requirement is greater than $250,000 (for FCMs). However, I can't override the net capital requirement on the Statement of the Computation of Minimum Capital Requirements.
13. WinJammer^TM is generating "errors" or "warnings" when I attempt to transmit. Why?
14. How do I transmit my completed statement to the NFA and/or CFTC (data entry is complete)?
15. How do I know my statement was successfully received by NFA and/or the CFTC?
16. I forgot my WinJammer^TM PIN. What do I do?
17. When I attempt to transmit, I'm unable to select the box for NFA and/or CFTC and enter the corresponding PIN?
18. What financial statements are required to be filed via WinJammer^TM?
19. What are my firm's financial statement filing requirements with the NFA and the CFTC.
20. Are IBs required to transmit financial statements to the CFTC?
21. I have a new computer. Do I need to re-install the WinJammer^TM software on my new computer?
22. My firm employs an outside accountant or an outside individual to complete our periodic financial statements. How does my firm provide our accountant with the tools to transmit our statement through WinJammer^TM?

1. My firm is applying for CFTC registration and NFA Membership. Is the initial applicant financial statement required to be submitted electronically via WinJammer^TM?

No, your initial financial statement can be submitted to NFA, and the CFTC if applicable, in hard-copy format.

All subsequent unaudited financial statements after your firm's registration becomes effective must be made via WinJammer^TM (for 1-FR-FCM and Focus filers) or EasyFile (for 1-FR-IB filers).

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2. My firm needs to sign-up for a WinJammer^TM PIN. What do I do?

Appropriate firm personnel must complete and sign the WinJammer^TM PIN agreement. Appropriate firm personnel is defined as an individual responsible for the firm's financial statements who is also a listed principal of the firm in NFA's Online Registration System ("ORS") and has an appropriate title as indicated in CFTC Regulation 1.10(d)(4). The exception is for firms that are also registered as Broker-Dealers. Broker-Dealers have the option of having an approved NASD Financial and Operations Principal ("FinOp") complete and sign the agreement and an approved FinOp principal is not required to be listed as a principal in ORS.

Applicant Broker-Dealer IBs must complete the IB PIN Agreement form and applicant FCMs must complete the FCM PIN Agreement. Applicant IBs that file form 1-FR-IB must use EasyFile. For more information on how to get set up with EasyFile see NFA's July 1, 2004 Member Advisory http://www.nfa.futures.org/compliance/070104.asp.

You can download a copy of the WinJammer^TM PIN agreement form at http://www.nfa.futures.org/compliance/winjammer.asp.

Completed forms should be sent to:

3. Who qualifies as an approved PIN signer for my firm?

Appropriate firm personnel must complete and sign the WinJammer^TM PIN agreement. Appropriate firm personnel is defined as an individual responsible for the firm's financial statements who is also a listed principal of the firm in NFA's ORS and has an appropriate title as indicated in CFTC Regulation 1.10(d)(4). The exception is for firms that are also registered as Broker-Dealers. Broker-Dealers may have an approved FinOp complete and sign the agreement and an approved FinOp principal is not required to be listed as a principal in ORS.

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4. My firm's PIN signer is no longer employed with my firm. What should I do?

The firm must appoint a new individual to be the firm's WinJammer^TM PIN signer. This newly appointed individual must complete and sign a new WinJammer^TM PIN agreement (see Question #3 regarding who qualifies as a PIN signer).

You can download a copy of the WinJammerTM PIN agreement form at http://www.nfa.futures.org/compliance/winjammer.asp.

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5. I submitted a WinJammer^TM PIN agreement, what's next?

Once NFA's Compliance Department receives a WinJammer^TM PIN agreement and determines that it is complete and an appropriate person has signed the agreement (see answer to Question #3 for appropriate firm personnel), the agreement will be processed and entered into NFA's system. As your confirmation, you will receive two e-mails, one with information to get the WinJammer^TM software and the second with the WinJammer^TM PIN files. If you do not receive these e-mails or have any questions regarding them, you may contact:

• Brian Rothfuss at (312) 781-1439 - brothfuss@nfa.futures.org
  
• Matt Lange at (312) 781-1432 - mlange@nfa.futures.org

6. I submitted a WinJammer^TM PIN agreement form but have not received any further information. Why?

Once NFA's Compliance Department receives a WinJammer^TM PIN agreement, analysis is performed to ensure the individual who completed the form is listed and approved as a principal of the firm or is an approved FinOp.

If you have still not received an e-mail confirmation subsequent to your submission, it is likely due to the following reasons:

• The individual who completed the form is not listed as a principal.
  
• The principal status of the individual who completed the form is "pending" (must be "approved" to process the agreement).
  
• The individual who completed the form is not listed as a principal and NFA could not find any evidence that the individual is a listed FinOp.
• The firm is an IB that files form 1-FR-IB and therefore must use EasyFile instead of WinJammer^TM (see NFA's 7/1/04 Member Advisory for more information about EasyFile on NFA's website at http://www.nfa.futures.org/compliance/070104.asp).

For further information concerning the status of your principal status, please contact NFA's Information Center (800) 621-3570. However, if you have been approved as a principal of your firm and/or you are a listed FinOp, please contact:

• Brian Rothfuss at (312) 781-1439 - brothfuss@nfa.futures.org
  
• Matt Lange at (312) 781-1432 - mlange@nfa.futures.org

7. The WinJammer^TM PIN file(s) e-mailed to me have been blocked by my e-mail software. Who can I contact for help?

WinJammer^TM PIN files are formatted as Microsoft Access files. It is likely that your e-mail software is viewing these files as potential computer viruses. If you are experiencing difficulties receiving your WinJammer^TM PIN file(s) via e-mail, you may contact:

• Brian Rothfuss at (312) 781-1439 - brothfuss@nfa.futures.org
  
• Matt Lange at (312) 781-1432 - mlange@nfa.futures.org
  
• Andrew Ohst at (312) 781-1364 - aohst@nfa.futures.org

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8. I am experiencing difficulties installing the WinJammer^TM software. Who can I contact for assistance?

For technical support or assistance in installing the WinJammer^TM software, you may contact NFA by calling (800) 621-3570 and our PC support staff will assist you.

Additionally, please note that for further guidance, the WinJammer^TM User Guide is available at: http://www.wjammer.com/newWeb/home.asp.

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9. I have installed the WinJammer^TM software on my computer. What's next?

Subsequent to installing the WinJammer^TM software program on your computer, the following steps must be completed prior to the submission of a financial statement:

• Create your Firm in the WinJammer^TM Program (See below).

• Import the correct WinJammer^TM form (See below).

• Import your firm's PIN file(s) (See below).

Create your Firm in the WinJammer^TM Program.
WinJammer^TM was developed to maintain information for multiple firms. Accordingly, before you can begin performing data entry for your initial filing, your firm profile must be created in WinJammer^TM.

To create a new firm, open the WinJammer^TM program, choose Setup from the main menu and then select Firms.

As pictured below, a Firm Maintenance box will appear, listing the current firms along with the unique identifier for the firm (usually the firm's taxpayer identification number).

Click the Add button on the Firm Maintenance window to add a firm.

As pictured below, the "Add New Firm" box will appear.

^* The unique ID option should only be chosen if the firm is a foreign entity that has neither a Tax ID nor a Social Security Number. If you need a unique identifier, contact NFA for the identifier.

The "Firm Maintenance" box will now reflect the information for the new firm.

Import the correct WinJammer^TM form
You need to ensure that the correct form (i.e. 1-FR-FCM, FOCUS II, or FOCUS IIA) has been downloaded from the WinJammer^TM web-site. Please note that WinJammer^TM statement forms can be downloaded at http://www.wjammer.com/newWeb/download.asp. Once you have downloaded the correct form to your computer, please follow the subsequent steps:

To install a form, open the WinJammer^TM program and choose Setup, Import New Form from the main menu. The "Import New WinJammer Form" box shown below will appear, listing the currently installed forms along with the version of the form.

^* Note: If you have not imported any forms into the program, no line items will be listed in the window. Also, please note that 1-FR-IB filers should no longer use WinJammer and instead should file using NFA's web-based EasyFile system. See NFA's 7/1/04 Member Advisory for EasyFile details on our website at http://www.nfa.futures.org/compliance/070104.asp.

The following box will be displayed so that you can select the import file for your form. Select the drive and path of your saved file:

Locate the file you want to import using this window and click the Open button.

^* Note: You should not unzip the file before importing it into WinJammer^TM.

After a .zip file is located and the open button is clicked, WinJammer^TM will begin importing the form. WinJammer^TM will display a status of the import and you will be notified when the import is complete (i.e. import successful).

The "Import New Form" box will now display the updated list of forms and applicable version number. If you need to import another form repeat the process, otherwise click Exit.

Import your firm's PIN file.
In order to submit your firm's financial statement, a valid PIN must be entered. The PIN serves as an electronic signature on the form. You will have a different set of PINs for each exchange and/or DSRO with which you are required to submit your financial statement. You should contact the respective exchanges and/or NFA if a new PIN needs to be issued to your firm.

In order to import PIN numbers, you must first receive the PIN file(s) via e-mail from NFA^*.

^* The PIN file(s) e-mail will be sent as soon as the WinJammer^TM PIN agreement is processed by NFA's Compliance Department. PLEASE NOTE: the WinJammer^TM PIN Signer must be approved as a listed principal or FinOp of the firm before the WinJammer^TM PIN agreement will be processed and the PIN file(s) sent.

The PIN files are named "NFAPIN.MD_" and "CFTCPIN.MD_". Broker-Dearler IBs will only receive the PIN file named "NFAPIN.MD_." FCMs will receive both PIN files, "NFAPIN.MD_" and "CFTCPIN.MD_."

Save the PIN file(s) to a folder on your computer, renaming the file extension from .MD_ to .MDB so the file names are NFAPIN.MDB and CFTCPIN.MDB.

Once you have acquired the PIN file(s) and are ready to import, complete the following:

Open the WinJammer^TM program and choose Setup, PINs from the WinJammer^TM Main menu. The box show below will appear.

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10. How do I complete a statement in WinJammer^TM (the software's installed, the firm information is set-up and the PIN file(s) are imported)?

After you have created your firm's profile and imported all PIN files into WinJammer^TM, you are ready to create your first financial statement and begin data entry. Complete the following steps to create a new WinJammer^TM form:

Create a New Form
To create a new form, choose File, New Form from the main menu. Or you can click Create New Form on the WinJammer toolbar. The "Create a New WinJammer Form" box, shown below, will appear.

Once the above information is entered, a cover sheet for the form type selected will be displayed. The first time a form is created for a firm, the cover sheet will be blank except for the firm name, the type of report, and ending date of the form.

After you complete the cover page information once, the cover sheet will be displayed with the default data filled in when subsequent statements are created. Only the beginning date of the report period must be completed when creating a new statement. All cover sheet data should be reviewed and updated as needed.

Entering Data
Data can be entered into text boxes which appear as white rectangular boxes on your computer screen.

Numbers that are displayed in blue without borders are calculated, carried forward, or numbers requiring itemization/explanation/reconciliation. These items cannot be directly manipulated.

Numbers that are displayed in blue can only be modified if they are accompanied with a related command button. To modify, you will need to click on the related command buttons (i.e. Description, List, Itemize, Explain, or Reconcile) that make up the values.

Open an Existing Form
The WinJammer^TM program provides you with the option to begin working on a statement and close the statement to continue data entry at a later time. In addition, WinJammer^TM also provides you with the ability to reopen completed statements^*.

^* Note that changes can only be made prior to the time of submission. If you wish to make changes subsequent to submission of the statement, you must create an amendment for the statement.

To open an existing form, select File, Open Form from the main menu or click Open Form on the WinJammer^TM toolbar and the following box will appear:

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11. How do I save the work I have done on my statement and work on it later?

The WinJammer^TM software program automatically saves all data as it is entered into the program. Therefore, you do not have to manually save data after it has been entered.

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12. Based on the number of associated persons ("APs") and branch offices ("BOs"), my firm's minimum net capital requirement is greater than $250,000 (for FCMs). However, I can't override the net capital requirement on the Statement of the Computation of Minimum Capital Requirements.

The 1-FR-FCM form was developed and is "owned" by the CFTC and the calculation for the minimum net capital requirement based on APs and BOs is derived from NFA Financial Requirements Section 1 (FCMs). Until the CFTC adopts the same rule, this calculation can not be applied to the forms in WinJammer^TM and you can not override the requirement.

Accordingly, when you enter a level of APs or BOs that increases your minimum net capital requirement beyond the $250,000 threshold for FCMs, the WinJammer^TM software will not reflect this increase in the Computation of Minimum Capital Requirements statement. Therefore, you need to be aware of this circumstance and perform a separate manual calculation to ensure that your firm is meeting its true capital requirement levels at all times.

Upon NFA's receipt of your financial statement, your minimum net capital requirement will be recalculated by NFA Compliance Department staff during the analysis of your firm's financial statement using the applicable financial requirements.

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13. WinJammer^TM is generating "errors" or "warnings" when I attempt to transmit. Why?

Prior to transmitting your financial statement the WinJammer^TM program automatically performs a "review" of your statement to search for potential data entry errors, mistakes or potential problems that may be contained within the financial statement. This review will generate a list of Warnings and Errors that you should address or review before transmitting the form. Problems noted by the WinJammer^TM review function can be classified by two different indicators, Warnings and Errors.

• Warnings are items that should be reviewed before transmitting. They represent questionable items but will not prevent you from transmitting. For example, a financial statement Warning would indicate that your firm has fallen below minimum net capital requirements (notice is required - contact NFA) or that your firm has fallen below its equity withdrawal restriction.

• Errors are items encountered during the edit check routine that must be corrected before you can transmit the form. For example, a financial statement Error could mean that your Balance Sheet does not balance correctly or the time period of the statement is incorrect. WinJammer^TM will prevent transmission of the statement if there are any errors.

WinJammer^TM also provides you with the option to "audit" the statement prior to transmission to test for Warnings and Errors. To "audit" an open statement, choose File from the main menu, then select Audit Form. Once WinJammer^TM has completed the "audit" process, a list of warnings and errors will be displayed as shown below.

14. How do I transmit my completed statement to the NFA and/or CFTC (data entry is complete)?

Please note that for further guidance the WinJammer^TM User Guide is available at: http://www.wjammer.com/newWeb/home.asp. The WinJammer^TM User Guide is also available within the WinJammer^TM application itself by clicking the F1 button or choosing Contents from the WinJammer^TM Help menu. To transmit your financial statement via WinJammer^TM complete the following steps:

Once your form is ready to be transmitted, choose File, Transmit Form from the WinJammer^TM main menu. The "Transmit a Form" box, show below, will appear.

Once all errors are corrected, the "Select Exchange(s) to transmit to" box, shown below, will prompt you to select the transmission destination.

By default, the transmission method will occur via the Internet. However, if you use AOL or another type of email that does not support MAPI or SMTP, you may need to use the File Method (contact NFA's Compliance Department for assistance at (800) 621-3570).

Once the transmission is complete, a box similar to the one shown below will appear.

From: NFA
Sent: Date
To: ABC Company
Cc:
Subject: NFA Filing Receipt confirmation

Thank you! Your filing was received by NFA on [DATE & TIME]
File name: 5A1B0000000A1F729F20031231IR0.wj

^* Note: The statement date is contained within the file name as the underlined portion above indicates.

Please do not assume your transmission was successful until you receive an e-mail confirmation each time you submit a financial statement as a late filing fee of $200 for each business day the financial statement is late will be assessed pursuant to NFA Financial Requirements, Section 10. http://www.nfa.futures.org/nfaManual/entireManual.asp#fins10

If you have not received a confirmation by the statement's filing due date, please contact NFA's Compliance Department for further assistance at (800) 621-3570.

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15. How do I know my statement was successfully received by NFA and/or the CFTC?

See answer to Question #14 above. It is important to ensure that your statement was received by NFA as a late filing fee of $200 for each business day the financial statement is late will be assessed pursuant to NFA Financial Requirements, Section 10.

http://www.nfa.futures.org/nfaManual/entireManual.asp#fins10

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16. I forgot my WinJammer^TM PIN. What do I do?

If you do not remember your firm's 4-digit, numerical WinJammer^TM PIN or you have general WinJammer^TM PIN inquires, you may contact:

• Brian Rothfuss at (312) 781-1439 - brothfuss@nfa.futures.org
  
• Matt Lange at (312) 781-1432 - mlange@nfa.futures.org

17. When I attempt to transmit, I'm unable to select the box for NFA and/or CFTC and enter the corresponding PIN?

It is likely that you did not import your firm's WinJammer^TM PIN file(s). Refer to the answer to Question #9 above for instructions on how to import you firm's PIN file. To request that your firm's WinJammer^TM PIN file(s) be emailed to you, contact:

• Brian Rothfuss at (312) 781-1439 - brothfuss@nfa.futures.org
  
• Matt Lange at (312) 781-1432 - mlange@nfa.futures.org

18. What financial statements are required to be filed via WinJammer^TM?

Once your firm's registration and membership are approved, all unaudited financial statements are required to be filed electronically via WinJammer^TM. All FCMs are required to file financial statements via WinJammer^TM on a monthly basis.

If your firm is also registered as a broker-dealer, you may file your FOCUS II or FOCUS IIA report via WinJammer^TM. If you file any of these broker-dealer forms you do not have to file the form 1-FR-IB or form 1-FR-FCM. Additionally, a Member IB that is required to file a financial statement with any other securities or futures SRO shall also file a copy of the statement with NFA (i.e. if you file your Focus Report quarterly with the NASD, you should file your Focus Report quarterly with NFA).

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19. What are my firm's financial statement filing requirements with the NFA and the CFTC.

All unaudited financial statement filings subsequent to registration are required to be submitted through WinJammer^TM (for 1-FR-FCM, Focus II and Focus IIA filers). Financial statement filing requirements are outlined in CFTC Regulation 1.10 and NFA Financial Requirement Section 1 and Section 5:

Future Commission Merchants (NFA Financial Requirements Section 1)
http://www.nfa.futures.org/nfaManual/entireManual.asp#fins1

Highlights from the rule: Each Member FCM for which NFA is the designated self-regulatory organization ("DSRO") must file financial reports with NFA for each month-end, including the fiscal year end, within 17 business days of the date for which the report is prepared. All financial reports, except those required to be certified by a Certified Public Accountant, must be filed electronically using WinJammer^TM.

Introducing Brokers (NFA Financial Requirements Section 5)
http://www.nfa.futures.org/nfaManual/entireManual.asp#fins5

Highlights from the rule: Each Member IB, except an IB operating pursuant to a guarantee agreement, must file financial reports with NFA semi-annually (every six months), including its fiscal year end, within 17 business days of the date for which the report is prepared. 1-FR-IB filers must submit using EasyFile. Additionally, a Member IB that is required to file a financial statement with any other securities or futures SRO shall also file a copy of the statement with NFA (i.e. a quarterly Focus Report filed with the NASD). All financial reports, except those required to be certified by a Certified Public Accountant, must be filed electronically using WinJammer^TM if you are a Broker-Dealer IB.

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20. Are IBs required to transmit financial statements to the CFTC?

No, IBs are not required to submit the 1-FR-IB (or FOCUS Report, if applicable) to the CFTC. IBs are only required to submit financial statements with NFA.

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21. I have a new computer. Do I need to re-install the WinJammer^TM software on my new computer?

Yes, if you have installed the WinJammer^TM software program on a local drive, you will need to re-install the software on your new computer.

To complete the re-installation, begin by saving, from your old computer, a file called "wj.mdb" to a disk or zip drive. To determine the location of this file choose Help from the main menu, then select About WinJammer. A box will appear called "About WinJammer" and the Data Location will display the folder that has this file.

You will then need to run the install program on the new PC (^*for instructions on how to install the WinJammer^TM software on you computer, see answer to Question #8 above).

Once WinJammer^TM has been installed on the new computer, copy the saved version of the "wj.mdb" file from the old computer over the one created on the new computer by the installation process. After copying the "wj.mdb" file from the old computer you will need to start WinJammer^TM and choose Setup from the main menu, then select Import new Form.

As pictured below, the "Import New WinJammer Form" box shown below will appear

You should now have all transmission, PIN and statement information that was on the old PC.

To access the Install program, or the Form Import files, you can download the most current versions from the WinJammer web-site at www.wjammer.com.

Note that if you originally installed WinJammer^TM so that the shared files are on a network server, you will only need to run the install program on the new PC.

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22. My firm employs an outside accountant or an outside individual to complete our periodic financial statements. How does my firm provide our accountant with the tools to transmit our statement through WinJammer^TM?

Many Members employ outside accountants and outside individuals who are not the PIN signers for the firm to complete the preparation of the financial statements. However, only the approved PIN signer (see Question #3 above) may submit the financial statement via WinJammer in accordance with CFTC Regulation 1.10(d)(4). Entering the PIN and submitting the statement is the equivalent of manually signing a hard copy of the statement and therefore only approved PIN signers should submit the statements.

NFA will not provide WinJammer^TM PINs or PIN files to any individual that is not the listed PIN signer for the firm.

If you do not remember your firm's WinJammer^TM PIN(s) or you need the WinJammer^TM PIN file(s) e-mailed to you, you may contact:

• Brian Rothfuss at (312) 781-1439 - brothfuss@nfa.futures.org
  
• Matt Lange at (312) 781-1432 - mlange@nfa.futures.org