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Notice I-14-07

February 12, 2014

Additional Reporting Requirements for Forex Dealer Members

In order to improve NFA's risk monitoring of Forex Dealer Members (FDMs), NFA is implementing new reporting requirements effective February 28, 2014. Under the new reporting requirements, FDMs will be required to report certain specified information to NFA on a monthly or quarterly basis through the monthly and quarterly FOREX reports filed through EasyFile. Help text is provided within the form to assist FDMs with the filing. The newly required information should be data that is readily available to FDMs.

Monthly Reporting Requirements

Monthly information will be due in the FOREX report filed each month. The first report will be due March 25, 2014 and will require information, as specified in the question, for the month of February or as of February 28, 2014. The newly required monthly information is as follows:

  • Identify entities where house commodity trading accounts were held and the number of accounts held at each entity (at any time during the prior month);
  • Identify all counterparties utilized by the firm to any repurchase or reverse repurchase agreements (at any time during the prior month);
  • Identify any non-trade based fees the firm charged to customers (at any time during the prior month);
  • Identify all forms of funding accepted by the firm for customer trading accounts (at any time during the prior month);
  • Identify all formal lines of credit held by the firm during the prior month and the amount of credit available from that line. Also report the total amount drawn from each line during the month regardless of whether the amount has been repaid;
  • Number of customer accounts whose trading volume represents 10% or more of the firm's overall trading volume (as of the month end reporting date);
  • Number of proprietary and non-customer accounts whose trading volume represents 10% or more of the firm's overall trading volume (as of the month end reporting date);
  • If the firm allows employees to engage in outside business activities; and
  • If the FDM offered any new products or services that the firm did not offer in previous monthly reporting period;

Quarterly Reporting Requirements

The first quarterly information will be required in the quarterly FOREX report dated March 31, 2014 and due on April 24, 2014. The new information includes:

  • Any material administrative, civil, enforcement, or criminal complaints or actions filed against the firm where such complaints or actions have not concluded, or any enforcement complaints or actions filed against the firm during the last three months;
  • Identify the five Associated Persons who generated the greatest revenue during the last 3 months; and
  • Frequency with which the firm performs scenario analyses to assess its financial condition and continued compliance with capital and other regulatory requirements (i.e., stress testing).

If you have any technical questions related the filings or EasyFile, please contact Brian Rothfuss, Senior Manager, Compliance (brothfuss@nfa.futures.org or 312-781-1439). Other questions on these requirements should be directed to John Brand, Managing Director, Compliance (jbrand@nfa.futures.org or 312-781-1465).

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