4s Submission Due Dates

Section 4s Final Implementing Rule Descriptions Rule References Effective Date of Regulation RDSS Call #

U.S. and Non-U.S. SDs and MSPs – 4s Submission Date

1 Chief Compliance Officer CEA Section 4s(k), CFTC Regulations 3.1 & 3.3 6/4/2012 4SK11 Due by Provisional Registration Date
2 Risk Management CEA Section 4s(j), CFTC Regulation 23.600 6/4/2012 4SJ11 Due by Provisional Registration Date
3 Business Continuity and Disaster Recovery CEA Section 4s(j), CFTC Regulation 23.603 6/4/2012 4SJ21 Due by Provisional Registration Date
4 Conflicts of Interest CEA Section 4s(j), CFTC Regulation 23.605 6/4/2012 4SJ31 Due by Provisional Registration Date
5 Disclosure of Information to CFTC and Antitrust CEA Section 4s(j), CFTC Regulations 23.606 & 23.607 6/4/2012 4SJ41 Due by Provisional Registration Date
6 Diligent Supervision CEA Section 4s(j) CFTC Regulation 23.602 6/4/2012 4SJ51 Due by Provisional Registration Date
7 Recordkeeping and Reporting CEA Section 4s(f) and (g), CFTC Regulation 23.201 to 23.205 6/4/2012 4SR11, 2 Due by Provisional Registration Date
8 Business Conduct Standards CEA Section 4s(h), CFTC Regulation 23.400 to 23.451 4/17/2012 4SH13, 8 Due by Provisional Registration Date
9 Swap Processing and Clearing CEA Section 4s(i), CFTC 23.506; and CEA Section 4s(j), CFTC Regulations 23.608 to 23.610 10/1/2012 4SI11, 4, 7 Due by Provisional Registration Date
10 Swap Documentation CEA Section 4s(i), CFTC Regulation 23.500 to 23.505 11/13/2012 4SI31, 5, 7 Due by Provisional Registration Date
11 Segregation of Collateral for Uncleared Swaps CEA Section 4s(l), CFTC Regulation 23.700 to 23.704 1/6/2014 4SL16 Due by Provisional Registration Date
12 Capital Requirements CEA Section 4s(e) TBD TBD TBD
13 Margin Requirements for Uncleared Swaps CEA Section 4s(e) TBD TBD TBD

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.

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