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August 09, 2013
Portfolio Reconciliation Requirements for Swap Dealers and Major Swap Participants
CFTC No-Action letter 13-40 deferred the compliance date for the portfolio reconciliation requirements set forth in Commission Regulations 23.502 until August 23, 2013. 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 Friday, August 23, 2013 if they have not already done so. SDs and MSPs relying on the Cross-Border Interpretive Guidance and Policy Statement and Exemptive Order regarding compliance with Portfolio Reconciliation requirements are not required to submit policies and procedures relating to Commission Regulations 23.502 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) filing code. 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.