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June 27, 2012
New Filing Requirements - Segregated Investment Detail Reports
Pursuant to NFA Financial Requirements Section 8, effective July 2, 2012, all NFA Member FCMs that hold customer futures and option segregated funds and/or foreign futures and foreign options secured amount funds will be required to file the Segregated Investment Detail Report (SIDR) as of the 15th (or the following business day if the 15th falls on a weekend) and the last business day of each month. The report is due by 11:59 P.M. Eastern time on the business day following the 15th and last business day of each month. The first SIDR under this requirement will report the information as of close of business on July 16, 2012 and must be filed by 11:59 P.M. Eastern time on July 17, 2012.
SIDR requires an FCM to provide the following information as of the reporting date:
The dollar amount of customer segregated funds held in cash and each type of permitted investment identified in CFTC Regulation 1.25(a);
The identity of each depository holding customer segregated funds and the dollar amount held at each depository;
The dollar amount of foreign futures and foreign option secured amount funds held in cash and each type of permitted investment identified in CFTC Regulation 1.25(a); and
The identity of each depository holding foreign futures and foreign option customer secured amount funds and the dollar amount held at each depository.
Additional guidance will be issued regarding the classification of funds separately itemized in SIDR prior to the due date of the first filing.
FCMs for which NFA is the DSRO currently file a monthly SIDR through NFA's EasyFile system. Beginning with the SIDR due on July 17, all SIDRs must be filed electronically through WinJammerTM. If the individual who currently files the monthly SIDR through EasyFile does not have access to WinJammerTM, a Security Manager of the firm will need to add the individual as a user via the Firm Maintenance page in WinJammerTM.
Beginning July 17, all FCMs are required to file daily segregation and secured amount statements, semi-monthly SIDRs and monthly financial statements with NFA. In order for NFA to receive the required filings from firms for which NFA is not the DSRO, the FCM must add NFA to the transmission list when the firm makes its July 17th filing. Specifically, when making the July 17th filing, the FCM's Security Manager must update the Firm Maintenance page in WinJammerTM and check the box next to NFA under Regulator Information.
On May 29, 2012, NFA submitted proposed Financial Requirements Section 16 and a related interpretive notice to the CFTC for its approval. Proposed Financial Requirements 16 specifically codifies the requirements in this notice as well as other requirements related to segregated and secured amount funds.
Please direct any SIDR questions to Valerie O'Malley, Senior Manager, Compliance at firstname.lastname@example.org or 312-781-1290 or Sharon Pendleton, Director, Compliance at email@example.com or 312-781-1401.