Notices to Members

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Notice I-16-14

May 4, 2016

Submission process for risk-based initial margin models for uncleared swaps for certain SDs and MSPs

Today, NFA begins accepting risk-based initial margin models (margin model) for review. See Notice to Members I-16-11 for an overview of the CFTC's final rules on the margin requirements for uncleared swaps of swap dealers (SD) and major swap participants (MSP) (CFTC's Margin Rules). These requirements allow SDs and MSPs subject to the CFTC's Margin Rules (CFTC Covered Swap Entity) to choose between using a standardized grid-based calculation for initial margin or a margin model approved by the CFTC or NFA.

As a reminder, NFA's review process of CFTC Covered Swap Entities' margin models involves a number of steps: exploratory discussions, margin model submission, review and assessment, and approval. See Notice to Members I-16-13 for an overview of this review process for CFTC Covered Swap Entities seeking NFA approval of a margin model by September 1, 2016, including the documents to be uploaded with each margin model submission.

Margin model submission system

The purpose of this Notice is to provide information on the system that CFTC Covered Swap Entities will use to submit margin model documentation. To begin the approval process and start exploratory discussions, CFTC Covered Swap Entities should contact Alessandra Riccardi, Director of Capital and Risk, to notify NFA that they are ready to submit an initial margin model for review. After exploratory discussions between NFA and the CFTC Covered Swap Entity, NFA will issue a letter to the firm that contains a unique link to the login page of NFA's EasyFile Margin Model Submission System1.


Once logged in, the Margin Model Submission System Filing Index will appear and authorized users should follow these steps to submit margin model documentation:

  1. Click on the date in the Creation Date column of the row that contains a form type of Margin Model, which will be pre-populated in your Filing Index.
  2. Filing Index

  3. Click "Browse" to select one or more files, and then "Upload Documents" to add these files to the filing. Uploaded documents must be one of the following file types: PDF, PPT, PPTX, XLS, XLSX, DOC, DOCX, ZIP, MSG, XML, CSV, JPG, GIF, PNG, TXT, HTML, HTM, ODT, ODG or VSD. The submitter must upload at least one document.
  4. If desired, enter details about the documents uploaded in the provided text box.
  5. Cover Page

  6. Click "Next" or "Submit Filing" to access the screen that will tell you whether or not errors were found. Correct errors, if applicable, by returning to the filing. Once there are no errors, click "Submit Filing" to submit the margin model documentation to NFA.
  7. Summary of Errors

  8. Review the confirmation screen, and click "Filing Index".
  9. Confirmation

  10. By returning to the Filing Index after reviewing the confirmation screen, you'll see both a Received Date and a status of Received associated with your filing.
  11. Search Results

  12. To amend the filing if needed, click the creation date, select "Amend Filing" from the top navigation, add a comment to explain your amended filing, and follow steps 1 through 6.

Once received, NFA will begin reviewing each CFTC Covered Swap Entity's margin model submission and conduct on-site reviews as necessary. Typically, firms should expect a 90-day turnaround for NFA's review of margin model submissions.

For more information on margin model submissions, including related resources, please visit NFA's website. If you have any questions regarding this Notice, please contact Alessandra Riccardi, Director of Capital and Risk ( or 212-513-6029).

1 Only authorized users of this system will have the capability to submit margin model documentation after NFA initiates the process. To become an authorized user of NFA's EasyFile Margin Model Submission System, contact your firm's ORS Security Manager.

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