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On May 24, the National Futures Association (NFA) issued Notice to Members 1-21-16, announcing the effective date for NFA Member swap dealer and major swap participant dues increases.

NFA Bylaw 1301 imposes annual dues on NFA Member swap dealers (SD) and major swap participants (MSP). The current annual dues amounts have remained unchanged, except for a reduction in MSP annual dues, since NFA established its swap regulatory program in 2013. Given the expansion of NFA’s swaps regulatory program over the past eight years and to fund its operations and maintain adequate reserves, NFA’s Board of Directors, on May 20, unanimously approved the following increases to these annual dues amounts:…
Continue Reading Effective Date for NFA Member Swap Dealer and Major Swap Participant Dues Increases

On March 31, the National Futures Association (NFA) issued Notice I-21-14 advising member firms that are registered with the Commodity Futures Trading Commission as swap dealers (SDs), that NFA rules adopting minimum capital and financial reporting requirements will become effective October 6.
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Continue Reading NFA Issues Notice Regarding Effective Date of NFA’s Swap Dealer Capital Requirements

By a vote of 3-2, on July 23, the Commodity Futures Trading Commission adopted its Final Cross-Border Swaps Rulemaking (Final Cross-Border Rule), which codifies several parts of the CFTC’s existing interpretive guidance and policy statement on the subject. Among other things, the Final Cross-Border Rule establishes key definitions, some of which are revised definitions of existing terms used in the interpretive guidance (e.g., the definition of “U.S. Person”) and others which are new. The rule also addresses which cross-border swaps must be considered for the purposes of the swap dealer registration threshold.…
Continue Reading CFTC Adopts Final Cross-Border Swap Rulemaking; Staff Issues No-Action Relief for ANE Transactions

On July 22, the Commodity Futures Trading Commission adopted rules (Final Rules) that set minimum financial capital requirements for swap dealers (SDs) and major swap participants (MSPs) that are not subject to prudential regulation (each, a “Covered Swap Entity” or CSE). The capital requirements were originally proposed in 2016, as explained in more detail here.

The core financial require…
Continue Reading CFTC Adopts Final Capital Requirements for Swap Dealers

On February 20, the Commodity Futures Trading Commission (CFTC) unanimously approved two proposed rules to revise its regulations relating to swap data reporting, dissemination and public reporting requirements for market participants.…
Continue Reading CFTC Approves Revisions to Swap Data Reporting, Dissemination and Public Reporting Requirements for Market Participants

On February 12, the Commodity Futures Trading Commission announced 2019 Examination Priorities (the “Examination Priorities”) for registrants of the Division of Market Oversight (DMO), Division of Swap Dealer and Intermediary Oversight (DSIO), and Division of Clearing & Risk (DCR). This marks the first time that the agency has published Examination Priorities for its divisions.…
Continue Reading CFTC Divisions Announce 2019 Examination Policies

The Division of Swap Dealer and Intermediary Oversight of the Commodity Futures Trading Commission has issued an advisory to remind swap dealers (SDs) and major swap participants (MSPs) of their swap data reporting obligations. The advisory lists examples of reporting issues that appear with some frequency, including readily apparent errors, incomplete reporting, duplicative swap reporting, calculation errors and reporting delays. The advisory also provides examples of reporting practices that SDs and MSPs may want to consider, including the implementation of data gatekeepers, automated review of reported data, erroneous record checks, improved change management practices, prompt data correction and proper supervision of third-party service providers.…
Continue Reading CFTC Reminds SDs and MSPs of Swap Reporting Obligations