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November 28, 2012
NFA Financial Requirements Section 16 - Additional Reporting Requirements Guidance
NFA Financial Requirements Section 16, which became effective on September 1, 2012, requires FCMs which hold customer segregated or secured amount funds to submit certain financial related information to NFA on a monthly, semi-monthly or daily basis. Effective November 30, 2012, reporting requirements for residual interest targets and leverage information will change.
NFA obtains the information required to calculate the FCM's measure of leverage through the supplemental schedule of the 1-FR or FOCUS filing. Most of the information required is automatically extracted from various statements within the filing. Beginning with the November 30, 2012 monthly filing due on December 26th, FCMs will be required to report assets not already included on the FCM's balance sheet (e.g. customer owned securities and customer option values). FCMs will report these amounts through the supplemental schedule as reconciling items to the total assets in the leverage calculation.
Residual Interest Targets
Currently, FCMs report the targeted residual amount for customer segregated and customer secured amount funds on the monthly supplemental schedule. Beginning November 30, 2012, FCMs will also report this information on the cover page of the daily segregation statement. This will allow FCMs to more timely report updated residual interest targets in the event that the firm revises its target amount. For the November 30, 2012 daily statement due on December 3rd, FCMs will report the targeted amounts. These amounts will carry over into future filings and FCMs will only be required to update the residual interest targets if the firm revises its targeted amounts.
If you have any questions concerning these requirements, please contact Valerie O'Malley, Senior Manager, Compliance (312-781-1290 or firstname.lastname@example.org) or Brian Rothfuss, Manager, Compliance (312-781-1439 or email@example.com).