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June 28, 2013
Portfolio Reconciliation Requirements for Swap Dealers and Major Swap Participants
In NFA's Notice to Members I-13-17, dated June 24, 2013, NFA reminded Members of the upcoming expiration of the CFTC's Interim Final Rule dated Dec. 18, 2012, which had deferred the compliance date for the portfolio reconciliation and swap trading relationship documentation requirements set forth in Commission Regulations 23.502 and 23.504. NFA stated that, due to the expiration of that Interim Final Rule, provisionally registered swap dealers ("SDs") and major swap participants ("MSPs") would be required to submit policies and procedures relating to those requirements no later than Monday, July 1, 2013.
Today, June 28, 2013, the CFTC issued Letter No. 13-40, which relates to the portfolio reconciliation requirements imposed on SDs and MSPs pursuant to Commission Regulation 23.502. That letter grants relief to all SDs and MSPs from the portfolio reconciliation requirements of Regulation 23.502 until August 23, 2013. Therefore, SDs and MSPs may, but are not required to, submit policies and procedures relating to those requirements at this time.
At this time, NFA does not possess information that would alter its Notice to Members I-13-17 with regard to swap trading relationship documentation requirements set forth in Commission Regulation 23.504.
Questions concerning the requirements should be directed to NFA's Information Center (firstname.lastname@example.org) at 800-621-3570 or 312-781-1410.