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November 15, 2019
Reminder: Dues surcharge for certain Member firms engaged in swaps activities effective January 1, 2020
In June 2019, NFA issued Notice to Members I-19-15 announcing the CFTC's approval of an annual dues surcharge of $1,750 on certain NFA Members including FCMs for which NFA is the DSRO, IBs, CPOs and CTAs that are approved as swap firms pursuant to NFA Bylaw 301(l)1.
Amendments to NFA Bylaw 1301 imposing this dues surcharge will become effective on January 1, 2020.
NFA invoices membership dues for the upcoming year approximately 45 days before the firm's membership renewal date, with payment required on or before this date. The dues surcharge will be invoiced to swap-approved or swap-pending Member firms for membership dues payable on or after January 1, 2020.
Withdrawal of swap-approved status
An NFA Member can check its swap approval status by accessing NFA's BASIC system.
To avoid this surcharge, a current or pending swap-approved Member firm that is not engaged in swaps activities and not required to be a swap-approved firm should withdraw its swap approval status by completing the Form 7-W using NFA's Online Registration System (ORS).
An authorized ORS user can access the Form 7-W by going to the ORS Links menu, selecting "Update/Withdraw Registration Information" and then clicking on "Process a Firm Withdrawal Request." Under the Withdrawal Categories section of the Form 7-W, check the box next to the Swap Firm category to withdraw the firm's swap approval status.
To ensure proper processing, NFA encourages firms to file the Form 7-W by December 1, 2019. However, any firm that withdraws its swap approval prior to the firm's 2020 renewal date will not be required to pay the dues surcharge.
More information on these amendments is available in the May 21, 2019 submission letter to the CFTC. If you have any questions regarding the new dues surcharge, please contact Tanika Pierre, Associate Director, Treasurer's Office (312-781-1383 or firstname.lastname@example.org). Questions regarding withdrawing as a swap-approved firm should be directed to NFA's Information Center (800-621-3570, 312-781-1410 or email@example.com).
1NFA Bylaw 301(l) requires FCM, IB, CPO and CTA Members engaged in activities involving swaps subject to the jurisdiction of the CFTC to be approved by NFA as swap firms, and their APs who engage in swaps-related activities to be approved as swap APs.