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September 21, 2021
Effective date for amendment imposing a late fee for certain SD filings and new Interpretive Notice clarifying existing SD filing requirements
NFA Financial Requirements Section 17 requires swap dealer (SD) Members to file certain financial, operational, risk management and other information with NFA. NFA has amended Financial Requirements Section 10 to impose a $1,000 per business day late fee on each financial report or other filing required by Financial Requirements Section 17 submitted after its due date. This late fee is consistent with the late fee NFA imposes on futures commission merchant, introducing broker and forex dealer Members that submit late financial filings.
NFA also adopted a new Interpretive Notice to Financial Requirements Section 17 entitled Financial Requirements Section 17: Initial Margin Model Ongoing Monitoring Reports clarifying NFA's expectations regarding quarterly and annual initial margin (IM) model performance reporting. The Interpretive Notice specifies the information currently required to be submitted and clarifies due dates for these filings.
The amendment to Financial Requirements Section 10 and the new Interpretive Notice will become effective on October 6, 2021.
NFA's Swap Participant Advisory Committee fully supported the proposed amendment to Financial Requirements Section 10 and the new Interpretive Notice, both of which were unanimously approved by NFA's Board.
NFA's August 23, 2021 submission letter to the CFTC contains more detailed information regarding the amendment and Interpretive Notice. If you have any questions, please contact George O'Donnell, Senior Risk Analyst II, OTC Derivatives (firstname.lastname@example.org or 212-513-6070) or Marcus Michelsen, Manager, Models & Risk (email@example.com or 212-346-5613).