Annual SD Requirements

Below is a listing of certain annual requirements for swap dealers (SD). This list serves as a reminder of certain yearly requirements and does not reflect all SD responsibilities.



  • Pay NFA dues (including a $100 registration records maintenance fee for each category of registration) on the SD's registration anniversary date.

Questionnaires and Updates

  • Complete NFA's Annual Questionnaire by the SD's membership anniversary date using NFA's Annual Questionnaire system. In the Annual Questionnaire, update the SDs Business Continuity and Disaster Recovery contact.
  • Complete the electronic Annual Registration Update in NFA's Online Registration System (ORS) when notified through NFA's Dashboard.


  • Designate a Chief Compliance Officer (CCO) and ensure the CCO is a listed principal of the SD. The CCO is required to prepare an annual report and provide the report to the SD's senior officer or the Board of Directors, and the CFTC. This report must be filed using WinJammerTM within 90 days of the SD's fiscal year end.
  • For Covered SDs, engage a certified public accountant to perform an audit of the firm's year-end financial statements (certified financial report). This report must be submitted through WinJammerTM.

Testing and Training

  • Test the disaster recovery plan and document any deficiencies found, any corrective action taken, and the date corrective action was taken.
  • Review and test the risk management program.
  • Approve risk tolerance limits (governing body).
  • Audit Swap Trading Relationship documentation.