Swaps Proficiency Requirements FAQs

For more information on navigating the Swaps Proficiency Requirements click here.

For information regarding technical requirements click here.

Information for Swaps Proficiency Requirements Administrators is available here.  

The following individuals are required to satisfy NFA's Swaps Proficiency Requirements:

  • Any individual registered as an associated person (AP) of a futures commission merchant (FCM), introducing broker (IB), commodity pool operator (CPO) or commodity trading advisor (CTA) who engages in swaps activity subject to the CFTC's jurisdiction.
  • With the exception of certain individuals acting as APs at swap dealers (SDs) in non-U.S. jurisdictions (as noted in the chart below), any individual who is acting as an AP at an SD as defined by the CFTC in subsection 6 of the Associated Person definition under CFTC Regulation 1.3. NFA's Swaps Proficiency Requirements in no manner alter this definition.

The chart below shows the applicability of NFA's Swaps Proficiency Requirements to individuals acting as APs at SDs based on the SD's location and type of counterparty. As shown in the chart below, NFA's Swaps Proficiency Requirements do not apply to individuals acting as APs at SDs in non-U.S. jurisdictions (including non-U.S. based branch offices of a U.S. SD) in specified circumstances.

Counterparty Type

Category A –
U.S. Person (other than a Non-U.S. Branch of an SD)
Category B – Non-U.S. Branch of a U.S. SD Category C – Non-U.S. Person Guaranteed by or Affiliate Conduit of a U.S. Person Category D – Non-U.S. Person Category A and
Category B, C or D
A U.S. AP of a U.S. SD (including an affiliate of a Non-U.S. person) with: Apply Apply Apply Apply Apply
An AP of a Non-U.S. Branch of a U.S. SD with: Apply Does Not Apply Does Not Apply Does Not Apply Apply
An AP of a Non-U.S. SD (including any Branch and affiliate of a U.S. person) with: Apply Does Not Apply Does Not Apply Does Not Apply Apply

 

An AP who engages in swaps transactions with a Category A counterparty must satisfy NFA's Swaps Proficiency Requirements regardless of whether the AP also engages in swaps transactions with counterparties from Categories B, C or D.

For example, an AP at a non-U.S. branch of a U.S. SD who only engages in swaps transactions with other non-U.S. branches of U.S. SDs would not be required to satisfy NFA's Swaps Proficiency Requirements. However, if that AP also engages in swaps transactions with a U.S. person (excluding a non-U.S. branch of a U.S. SD), then the AP would be required to satisfy NFA's Swaps Proficiency Requirements.

APs of non-U.S. SDs (including non-U.S. SDs that are affiliates of a U.S. person) whose counterparties are limited to non-U.S. branches of U.S. SDs and non-U.S. persons are not required to satisfy NFA's Swaps Proficiency Requirements.

NFA's Swaps Proficiency Requirements have two tracks: the Long Track and the Short Track. Each Track is module based and contains both a learning component and a testing component.    

The Long Track consists of eight modules and a total of 100 test questions:

  • Swap Products and Applications (20 test questions)
  • Regulation of the Swaps Market (20 test questions)
  • Onboarding (10 test questions)
  • Transactional Disclosures (10 test questions)
  • Anti-Fraud and Ethical Practices (10 test questions)
  • Trade Execution/Clearing/Margin (10 test questions)
  • Risk Management (10 test questions)
  • Supervision (10 test questions)

 The Short Track consists of four modules and a total of 60 test questions: 

  • Swaps Products and Applications (20 test questions)
  • Regulation of the Swaps Market (20 test questions)
  • Supervision (10 test questions)
  • Compliance, Anti-Fraud, and Other Requirements (10 test questions)

The testing component of the modules is based solely on the content presented in the modules' learning component.  Therefore, there is no need for additional training or study guides to complete NFA's Swaps Proficiency Requirements. 

Individuals Acting as APs at SDs

In general, SDs must ensure that individuals acting as APs satisfy the Long Track. SDs must also ensure that individuals responsible for supervising individuals acting in the capacity of APs satisfy the Long Track.

Some SDs have designated as APs individuals who are not in the SD's sales and trading areas and who do not negotiate, price and/or execute swaps with counterparties on behalf of the SD or manage the SD's swaps-related risks (sales and trading activities). For these individuals designated as APs, the SD has the option of requiring the individual to satisfy the Long Track or the Short Track. Similarly, for individuals supervising persons designated as APs but engaged in activities that do not involve sales and trading activities, the SD has the option of requiring those supervising individuals to take the Long Track or the Short Track.

Swap APs at Intermediary Firms – FCMs, IBs, CPOs an CTAs

Individuals approved as or applying for approval as an FCM, IB, CPO or CTA Member swap firm or swap associated person of an FCM, IB, CPO or CTA Member (intermediary swap AP) are required to satisfy the Short Track.  

Individuals who are responsible for supervising intermediary swap APs are also required to satisfy the Short Track.

The Compliance Date to satisfy NFA's Swaps Proficiency Requirements is January 31, 2021. NFA's rules requiring that APs satisfy the Swaps Proficiency Requirements will become effective on January 31, 2020, at which time APs will be able to access and take the Swaps Proficiency Requirements online. Individuals who are currently approved as a swap AP at an FCM, IB, CPO or CTA Member firm or act as an AP at an SD and intend to continue acting in this capacity after the Compliance Date have until January 31, 2021 to satisfy the applicable NFA Swaps Proficiency Requirements.

Those individuals who do not satisfy the applicable Swaps Proficiency Requirements by the Compliance Date will not be able to act as a swap AP until NFA's Swaps Proficiency Requirements have been satisfied. Additionally, if a swap AP at an intermediary Member firm does not satisfy the Requirements by the Compliance Date, the individual's swaps approval status will be changed to pending.

Individuals seeking to engage in swaps activities at an FCM, IB, CPO or CTA Member firm after the Compliance Date must satisfy NFA's Swaps Proficiency Requirements in order to be approved as a swap AP and to engage in swaps activities per NFA Bylaw 301(j).  SDs must ensure that individuals seeking to act as an AP at an SD after the Compliance Date have satisfied NFA's Swaps Proficiency Requirements prior to engaging in activities that require AP designation.

An intermediary swap AP or AP of an SD (collectively, swap AP) who successfully completes the Short Track and moves into a role requiring completion of the Long Track may satisfy NFA's Swaps Proficiency Requirements by completing the remaining modules of the Long Track. Swap APs who have successfully completed the Short Track and wish to satisfy the Long Track should ask their firm to contact NFA's Information Center 312-781-1410 or 800-621-3570 or information@nfa.futures.org).

An AP of an SD who is also an intermediary swap AP must successfully complete the Long Track in order to satisfy NFA's Swaps Proficiency Requirements if the SD requires that the individual satisfy the Long Track.

A swap AP who satisfies the Long Track and then transfers to a role that only requires the Short Track will be deemed to have satisfied the Swaps Proficiency Requirements.

An individual will not have to satisfy NFA's Swaps Proficiency Requirements again, provided the Track previously completed satisfies the Track required by the individual's new position and, since the date the individual satisfied NFA's Swaps Proficiency Requirements, there has been no two year period during which the individual was not employed by an NFA Member SD (or its affiliated entity) or approved as a swap AP at an intermediary swap firm.

If the individual satisfies the condition described above but previously satisfied the Short Track and will be acting in a capacity that requires that the individual satisfy the Long Track, the individual will only need to take and pass the remaining modules of the Long Track.

NFA's Swaps Proficiency Requirements will be administered online.  Individuals will not be required to travel to a separate testing location. Firms should ensure that their employees are able to access the following website to take the Swaps Proficiency Requirements:  https://nfa-swaps-proficiency-requirements.moonami.com.

A Swaps Proficiency Requirements Administrator (SPR Admin) is an individual designated by a Member firm who is responsible for coordinating the enrollment of individuals from a Member firm in NFA's Swaps Proficiency Requirements.

NFA estimates that the Long Track can be completed in approximately eight hours and the Short Track in approximately four hours. APs will be required to go through the learning component and then pass the testing component for each module. There is no time limit to complete each module. You may exit and re-enter the training or testing component of NFA's Swaps Proficiency Requirements at any time and the system will automatically save your progress. Your progress will also be saved if you are logged out by the system due to a period of inactivity. Once you begin the test component you may not reenter the learning component. Your firm will be able to track your progress through NFA's Online Registration System (ORS).

NFA recognizes that the estimated completion times for the Short Track and Long Track are significant time commitments. To minimize interruption to daily job functions, individuals may complete all of the required modules in one sitting or may complete the required modules one at a time, as their time and schedule permit, so long as all required modules are completed by the Compliance Date (January 31, 2021). In addition, individuals may retake each learning and testing component as many times as necessary in order to pass. After the Compliance Date, individuals may continue to take the modules one at a time, however, all modules must be successfully completed prior to engaging in activities that require designation as an AP at an SD or being approved as a swap AP at an FCM, IB, CPO or CTA Member.

Individuals Associated with an NFA Member Firm

There is no fee to enroll in NFA's Swaps Proficiency Requirements for individuals associated with an NFA Member SD or swap-approved FCM, IB, CPO or CTA. The cost of enrollment in NFA's Swaps Proficiency Requirements for these individuals is included in annual SD and FCM, IB, CPO and CTA membership dues.  

Individuals Not Associated with an NFA Member Firm

Individuals who are not associated with an NFA Member firm but seek to satisfy NFA's Swaps Proficiency Requirements for professional or other reasons are required to pay a fee of $100 to take either the Long Track or the Short Track. Payment can be made using Visa and MasterCard debit or credit cards and American Express and Diner's Club credit cards.

Individuals associated with a Member firm will either be directly enrolled by their firm or will be provided an enrollment code to enroll individually. Individuals directly enrolled by their firm will receive an email with login information to access NFA's Swaps Proficiency Requirements. Individuals who receive an Enrollment Code from their firm can view the instructions, "How to Enroll Using an Enrollment Code" (PDF).
Individuals not associated with a Member firm may enroll online at https://nfa-swaps-proficiency-requirements.moonami.com on or after the January 31, 2020 effective date.

Individuals affiliated with an NFA Member firm should contact appropriate personnel at their firm. Individuals not affiliated with an NFA Member firm should contact NFA's Information Center (312-781-1410 or 800-621-3570 or information@nfa.futures.org).

Please contact appropriate personnel at your firm.
No. Although individuals may take the modules at their own pace, the learning component of the modules must be viewed prior to entering the test for each module. Modules will appear in the order set forth in their assigned/chosen Track (Long or Short), with the learning component of the module followed by the testing component. Individuals will be not be able to access the next module in the Track until they have viewed the previous module's learning component and completed the test for that module. Individuals will complete modules one by one as they follow through their assigned Track.

Individuals must achieve a score of 70 percent or greater on each module within the individual's assigned/chosen track in order to receive a Certificate of Completion.

A score of 70 percent or greater is required to pass each module. An individual who receives a score of less than 70 percent on any module will be prompted to retake the failed module after the individual has completed the remaining modules in the Track.   There is no waiting period to retake modules. The individual will retake any failed modules in the order in which they appeared in the individual's Track.
No. The test questions are randomized and individuals will be asked different questions on subsequent attempts. Please note that test answers are also randomized and individuals should pay close attention to answer the test questions correctly. Additionally, for security reasons, NFA does not disclose which questions an individual answered incorrectly or answers to any of the test questions.

A Member firm's authorized ORS users may verify an individual's proficiency status in ORS using the Completion Date by Individual Report. If the individual is a registered swap AP, authorized ORS users can also check the individual's ORS record.

Authorized ORS users can also track the progress of their employees in ORS using the Individual Status by Firm Report.

After January 31, 2021, firms may verify the proficiency status of individuals who are registered APs by checking BASIC.  At that time, designation as a swap AP in BASIC will indicate successful completion of the Swaps Proficiency Requirements.

NFA's Swaps Proficiency Requirements have been developed to provide flexibility and accessibility by allowing individuals to complete the Requirements from any location using a personal or work computer and providing individuals unlimited time to complete each module. Given these features, most individuals who have required accommodations in the past to satisfy NFA's other proficiency requirements will no longer require accommodations to complete the Swaps Proficiency Requirements. If you require special accommodations to take NFA’s Swaps Proficiency Requirements beyond what the Requirements or your firm provide, please contact NFA’s Information Center (312-781-1410 or 800-621-3570 or information@nfa.futures.org).
NFA's Swaps Proficiency Requirements is only offered in English.
No. Similar to the Series 3 and Series 34 proficiency requirements for futures and forex APs, there is no continuing education component to NFA's Swaps Proficiency Requirements.

When you access NFA's Swaps Proficiency Requirements, we request personal information from you necessary to verify your identity, to maintain the accuracy of NFA's records, and to provide Member-facing and/or public-facing information about you and your completion of the Swaps Proficiency Requirements. Although not required to access NFA's Swaps Proficiency Requirements, the furnishing of the last four digits of a social security number assists NFA in identifying individuals who have completed them.

The following types of personal information are collected from individuals accessing the Swaps Proficiency Requirements:

  • Name
  • Email address
  • Last four digits of social security number (optional)
  • Date of birth
  • NFA ID (if applicable)
If you have questions regarding NFA's Swaps Proficiency Requirements, please contact NFA's Information Center (312-781-1410 or 800-621-3570 or information@nfa.futures.org). NFA's Information Center representatives are available from 8:00 a.m. to 5:00 p.m. Central Time, Monday through Friday.