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June 24, 2013
Portfolio Reconciliation and Swap Trading Relationship Documentation Requirements for Swap Dealers and Major Swap Participants
In its December 18, 2012 Interim Final Rule, the CFTC deferred until June 30, 2013 the compliance date for the portfolio reconciliation and swap trading relationship documentation requirements set forth in Commission Regulations 23.502 and 23.504. Accordingly, provisionally registered swap dealers ("SDs") and major swap participants ("MSPs") are required to submit policies and procedures relating to those requirements no later than Monday, July 1, 2013 if they have not already done so. SDs and MSPs relying on the Final Exemptive Order Regarding Compliance With Certain Swap Regulations are not required to submit policies and procedures relating to Commission Regulations 23.502 and 23.504 with respect to trades with non-US counterparties at this time. Required submissions should be made to NFA's Registration Documentation Submission System ("RDSS") through the 4SI5 (portfolio reconciliation) and 4SI7 (swap trading relationship documentation) filing codes. For more information about these requirements, the RDSS system and the filing codes, visit the compliance page for SDs and MSPs on NFA's website.
NFA has recommended that policies and procedures be submitted prior to the required submission date to allow time for NFA staff to confirm receipt of responsive materials and to accommodate potential follow-up with SDs and MSPs in the event of an incomplete submission. At a minimum, policies and procedures must be submitted to the RDSS system no later than 6:00 p.m. EST on the submission date in order for staff to confirm receipt of required documents ahead of overnight processing.
Questions concerning the requirements should be directed to NFA's Information Center (firstname.lastname@example.org) at 800-621-3570 or 312-781-1410.