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February 18, 2015
SD and MSP requirements – Annual Questionnaire and Business Continuity and Disaster Recovery Plan contact information
All NFA Members, including Swap Dealers (SD) and Major Swap Participants (MSP) are required to complete NFA's Annual Questionnaire, which provides NFA with important information regarding a firm's business activities. Beginning April 1, 2015, each SD and MSP will be required to complete the SD-MSP Questionnaire as part of the firm's annual membership renewal process. NFA also encourages SDs and MSPs to keep the questionnaire data current throughout the year. SDs and MSPs can access the SD-MSP Questionnaire by logging into NFA's Annual Questionnaire system and choosing the link to the "SD-MSP Questionnaire" in the Questionnaire Index.
Business Continuity and Disaster Recovery Plan - Contact Information
Under the CFTC's Business Continuity and Disaster Recovery Plan (BCDR) requirements, each SD and MSP is required to provide the CFTC with contact information for two employees with the authority to make key decisions on behalf of the SD or MSP, with knowledge of the firm's BCDR plan, and whom the CFTC can contact in the case of an emergency or other disruption. When completing this year's Annual Questionnaire, NFA is requiring each SD and MSP to provide NFA with the contact information for these two employees, as well as contact information for three additional employees with the same authority and knowledge. The firm must include its Chief Risk Officer as one of the employee contacts.
The BCDR emergency contact information must be submitted through the WinJammer™ system, which firms may sign into directly or link to through the Questionnaire Index in NFA's Annual Questionnaire system by selecting "Firm Disaster Recovery." Going forward, SDs and MSPs are required to promptly notify NFA and the CFTC of any changes to this information through the WinJammer™ system. Additionally, as part of its annual membership renewal process, each SD and MSP will be required to ensure that the information is current and, if not, immediately submit any changes.
If you have any questions related to completing the Annual Questionnaire, please contact Shuna Awong, Director, OTC Derivatives (firstname.lastname@example.org or 212-513-6057), Cliffe Allen, Director, OTC Derivatives (email@example.com or 212-346-5634) or Michael Brosius, Director, OTC Derivatives (firstname.lastname@example.org or 312-781-7475).
Questions related to filing the BCDR emergency contact information through WinJammer™ should be directed to Jamie Syrek, Systems Manager, OTC Derivatives (email@example.com or 312-781-1577).