How to Fill Out and File NFA Form 8-R: Fingerprints, Exam, and Review

NFA Form 8-R is the individual application used to register with the Commodity Futures Trading Commission as an associated person, principal, floor broker, or floor trader, and your sponsoring firm files it electronically for you through the National Futures Association’s Online Registration System. The application costs $85, requires fingerprints and a background check, and for most associated persons requires a proficiency exam. The step that trips people up is not the form itself but the 20-day window that follows: once your sponsor files, NFA issues a temporary license that lets you start working, but that license is withdrawn if fingerprints, fee, your personal verification, and exam evidence don’t arrive within 20 days.

Who Has To File

Form 8-R applies to every individual whose role in the derivatives markets requires CFTC registration. Associated persons — people who solicit customer orders or supervise those who do at a futures commission merchant, retail foreign exchange dealer, introducing broker, commodity trading advisor, or commodity pool operator — are the largest group.¹ Floor brokers and floor traders register on the same form.²

Principals file too. Under NFA Registration Rule 101, a principal includes any director, president, chief executive officer, chief operating officer, chief financial officer, chief compliance officer, or person in charge of a regulated business unit. It also reaches anyone who directly or indirectly owns, controls the voting of, or can direct the sale of 10 percent or more of the firm’s equity securities, or who is entitled to 10 percent or more of its net profits.³

If your activity is limited to swaps under CFTC jurisdiction, you still file Form 8-R, but your proficiency requirement is different: NFA’s Swaps Proficiency Requirements are completed online rather than through the Series 3.⁴

You cannot file on your own. Every applicant needs a sponsor firm, and the sponsor’s authorized representative submits the form and certifies your fitness for the role.⁵

Settle Your Proficiency Exam Status First

Most associated person applicants must pass the National Commodity Futures Examination — the Series 3 — before or shortly after their sponsor files Form 8-R. The exam fee is $140. If you passed it within the last two years, you’re covered. You also get credit for an older passing score as long as you haven’t had a continuous gap of more than two years without registration as an AP, floor broker, FCM, IB, CPO, or CTA that is an NFA Member.⁶

Alternatives exist for specific situations. The Series 31 covers you if you’re already a FINRA-registered General Securities Representative at an NFA Member FCM or IB and your futures activity is limited to soliciting funds for commodity pools, soliciting discretionary CTA accounts, or supervising those activities. The Series 32 is available if you were registered or licensed to solicit futures business in the United Kingdom or Canada within the two years before your application. No exam is required if you’re a FINRA-registered General Securities Representative at an NFA Member firm and your futures activity is limited to referring clients to that sponsor’s APs. Under Registration Rule 402, NFA may waive the exam for APs of CPOs that registered only because their pools primarily trade securities, or CTAs that registered only because their futures advice is for risk management. Currently registered floor brokers are exempt from the Series 3.⁶

What To Gather Before Your Sponsor Files

The form asks for your Social Security number, date of birth, and a complete employment history covering the past 10 years with no unexplained gaps longer than one month. Periods of unemployment or schooling need to be documented and described. You’ll also list every physical residential address for the past five years.⁷

The disciplinary disclosure section produces most of the trouble. The form asks yes-or-no questions about criminal matters, regulatory actions, civil litigation involving investment activity, financial events like bankruptcies, and employment terminations. Common failures include leaving off criminal charges that were later dismissed after probation, regulatory matters reported to another self-regulatory authority, and situations where the applicant told their firm about a disclosable matter but it never reached the form.⁸ Undisclosed issues are treated far more seriously than disclosed ones.

Every “yes” answer requires a separate Disclosure Matter Page filed through NFA’s DMP Filing System. Each DMP describes the specific event, including a docket number where one exists, and must be accompanied by supporting documents. For criminal matters, NFA expects the full court file: complaint, plea or plea agreement, judgment, sentence, proof that you satisfied the sentence, and the final outcome. If court documents are unavailable, you’ll need a certified letter from the court confirming that.⁹ The DMP Filing System doesn’t open to you until after Form 8-R has been submitted, so assemble the supporting documents in advance and be ready to upload them promptly.

Fingerprints

NFA requires FBI fingerprint cards for the criminal history check. Applicants currently mail physical cards, and NFA recommends sending three sets in case reprocessing is needed. The address is:¹⁰

NFA
Attention: Registration Department
320 South Canal, Suite 2400
Chicago, IL 60606

Effective October 1, 2026, NFA is transitioning to Fieldprint as its designated electronic fingerprinting provider. After that date, applicants submit fingerprints through Fieldprint rather than mailing cards. If you’re filing near that date, check NFA’s fingerprint card requirements page for current instructions.

How the Filing Happens

Your sponsor’s authorized representative files Form 8-R electronically through NFA’s Online Registration System. NFA no longer accepts hard-copy applications for APs or principals.¹¹ The sponsor needs a designated Security Manager with secure ORS access to start the filing.¹

In filing, the sponsor certifies that the information is, to the best of the sponsor’s knowledge, true, complete, and accurate; that you authorized the electronic filing; and that the sponsor performed its own due diligence on your background.⁵

The application fee is $85 and non-refundable, for both AP applicants and principals. It is waived if you’re already registered with the CFTC in any capacity or currently listed as a principal of a CFTC registrant.¹¹²

The 20-Day Temporary License Window

The moment your sponsor files, NFA grants AP applicants a temporary license, and you can start working in a registered capacity. The license comes with a hard deadline. Within 20 days of the filing date, NFA must receive your fingerprint cards, the $85 registration fee, your personal verification of the application, and, if applicable, evidence from FINRA that you’ve passed the required proficiency exam.¹³

Miss any piece at the 20-day mark and the temporary license is withdrawn. Your status reverts to pending, and you must stop all activities that require registration until the application is fully processed. Most withdrawals happen for logistical reasons: a fingerprint card in the mail, a fee that hasn’t posted, a verification not returned. Not a background problem.

Floor brokers and individual floor traders can also receive temporary licenses, with one added step: NFA must first receive notice that a contract market has granted trading privileges.¹³

If you don’t receive a temporary license, or yours was withdrawn, NFA gives you 90 days from the initial filing to clear up deficiencies. If the application is still incomplete at that point, it will be withdrawn entirely.¹⁴

Background Check and Review

Once NFA receives your fingerprint cards, it forwards the images to the FBI for a criminal history check. Results are compared against your disclosures. If NFA identifies discrepancies, expect a request for written explanations and supplemental documentation. Failure to provide complete documents will delay the process and can result in denial.⁵

What Can Disqualify You

Certain items in your background can lead to denial. Under Section 8a(2) of the Commodity Exchange Act, the CFTC may refuse, condition, suspend, or revoke registration for anyone involved in serious financial crimes, including embezzlement, theft, extortion, fraud, misappropriation, and bribery.¹⁵

NFA Bylaw 301 adds further grounds that make a person ineligible for membership or association with a Member firm. Prior suspension or expulsion from a registered futures association or contract market for conduct inconsistent with just and equitable principles of trade will disqualify you. So will being subject to a CFTC order denying, suspending, or revoking registration, or barring you from association with an FCM. Having registration in any capacity refused within the five years before your application is a bar. So is being permanently or temporarily enjoined by any court from acting as an FCM, IB, floor broker, CTA, CPO, associated person, securities broker-dealer, investment adviser, or from engaging in commodity futures or securities activities. Associating with someone you know, or should know, to be ineligible under these criteria can itself be a basis for disqualification.¹⁶

After You’re Registered

Registration isn’t static. When your personal information changes — a new address, a new employer, or a new legal matter that would change a disclosure answer — you tell your sponsor, and the sponsor files the update in ORS.⁵

Leaving a Firm

When you leave a sponsor, the sponsor must file an electronic Form 8-T (Individual Withdrawal Notice) within 30 days of your termination date. Missing that deadline triggers a $100 late filing fee. The sponsor must also promptly give you a copy of the withdrawal notice.¹⁷

If you move to a new firm, the new sponsor files a fresh Form 8-R for you. Your prior registration history carries forward in NFA’s records, and because you’re already registered with the CFTC, the $85 fee is waived. You can hold temporary licenses with more than one sponsor at the same time, so transitioning between firms doesn’t have to create a gap in your ability to work.¹³

1
National Futures Association. Associated Person (AP) Registration
2
Commodity Futures Trading Commission. Registration of Intermediaries
3
National Futures Association. NFA Registration Rules – Part 100 Definitions
4
National Futures Association. NFA Swaps Proficiency Requirements
5
Reginfo.gov. NFA Form 8-R Individual Application Template
6
National Futures Association. Proficiency Requirements
7
Commodity Futures Trading Commission. Adoption of Revised Registration Form 8-R
8
National Futures Association. Failure to Disclose Disciplinary Information on a Registration Application
9
National Futures Association. Disciplinary Information FAQs
10
National Futures Association. Fingerprint Card Requirements
11
National Futures Association. Filing Applications in NFA’s Online Registration System (ORS) FAQs
12
National Futures Association. Principal Status
13
National Futures Association. Temporary Licenses FAQs
14
National Futures Association. ORS User Guide for Firm or Sole Proprietor
15
Commodity Futures Trading Commission. Registration and Compliance Requirements for Commodity Pool Operators and Commodity Trading Advisors
16
National Futures Association. NFA Bylaw 301 – Requirements and Restrictions
17
National Futures Association. Filing Firm Withdrawal Requests and Notices of Individual Withdrawals in NFA’s ORS FAQs