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Section 4s Due Dates Footnotes

1 Substituted compliance may be available for non-U.S. SDs and MSPs. The CFTC issued limited comparability determinations for specific 4s implementing regulations. For more information see summary of Entity-Level Comparability Determinations published by the CFTC and complete comparability determinations published in the Federal Register.

2 The RDSS Call # 4SR1 for Recordkeeping and Reporting incorporates the following RDSS Call #s that have been deactivated as of March 9, 2015: 4SR2, 4SR3, 4SR4, 4SR5, 4SR6, 4SR7, 4SR8, 4SR9, 4SR0, 4SRA, 4SRB, 4SRC, and 4SRD. The RDSS Call # 4SR1 shall be utilized to address all applicable 4s requirements in CFTC Regulations 23.201 to 23.205. 

3 The RDSS Call # 4SH1 for Business Conduct Standards incorporates the following RDSS Call #s that have been deactivated as of March 9, 2015: 4SH2, 4SH3, and 4SH4. The RDSS Call # 4SH1 shall be utilized to address all applicable 4s requirements in CFTC Regulations 23.400 to 23.451.

4 The RDSS Call # 4SI1 for Swap Processing and Clearing incorporates the following RDSS Call #s that have been deactivated as of March 9, 2015: 4SI2 and 4SIC. The RDSS Call # 4SI1 shall be utilized to address all applicable 4s requirements in CFTC Regulations 23.506, and 23.608 to 23.610.

5 The RDSS Call # 4SI3 for Swap Documentation incorporates the following RDSS Call #s that have been deactivated as of March 9, 2015: 4SI4, 4SI5, 4SI6, 4SI7, 4SI8, 4SI9, 4SI0, 4SIA, and 4SIB. The RDSS Call # 4SR1 shall be utilized to address all applicable 4s requirements in CFTC Regulations 23.500 to 23.505.

6 The RDSS Call # 4SL1 for Segregation of Collateral for Uncleared Swaps incorporates the following RDSS Call #s that have been deactivated as of March 9, 2015: 4SL2. The RDSS Call # 4SL1 shall be utilized to address all applicable 4s requirements in CFTC Regulations 23.700 to 23.704.

7 Category A Transaction-Level Requirements apply to non-U.S. SDs and MSPs (including an affiliate of a U.S. person) with respect to swaps with U.S. persons. These requirements do not apply to non-U.S. SDs and MSPs with respect to swaps with non-U.S. persons not guaranteed by, and not an Affiliate Conduit of a U.S. person.

8 Category B Transaction-Level Requirements do not apply to non-U.S. SDs and MSPs (including an affiliate of a U.S. person) with respect to swaps with: foreign branches of U.S. Bank that is a SD or MSP; non-U.S. person guaranteed by, or an Affiliate Conduit of a U.S. person; or non-U.S. person not guaranteed by, or not an Affiliate Conduit of a U.S. person.

9 CFTC initial and variation margin requirements apply to each SD and MSP that is not subject to oversight by a prudential regulator (CFTC Covered Swap Entity), as defined in the Dodd-Frank Act, including non-bank subsidiaries of bank holding companies and non-US firms subject to foreign prudential regulation.

10 The compliance date is determined by CFTC Regulation 23.161. The earliest compliance date is September 1, 2016. Each CFTC Covered Swap Entity that surpasses the threshold identified in the CFTC's final rules on the margin requirements for uncleared swaps of swap dealers and major swap participants (CFTC's Margin Rules) will be required to submit policies and procedures no later than the applicable compliance date. For more information on intial margin models for uncleared swaps, please visit NFA's website.

11 The compliance date is determined by CFTC Regulation 23.161. The earliest compliance date is September 1, 2016. Each CFTC Covered Swap Entity that surpasses the threshold identified in the CFTC's Margin Rules will have a variation margin compliance date of September 1, 2016. All other registrants will have a variation margin compliance date of March 1, 2017.

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