Portfolio Reconciliation and Swap Trading Relationship Documentation Requirements for SDs and MSPs


Provisionally registered swap dealers (SDs) and major swap participants (MSPs) are required by the National Futures Association (NFA) to submit portfolio reconciliation and swap trading relationship documentation policies and procedures that have been adopted by the SD or MSP pursuant to Commodity Futures Trading Commission Regulations 23.502 and 23.504. Required submissions must be made to the NFA’s Registration Documentation Submission System (RDSS) through the appropriate filing codes no later than 6:00 p.m. EST on July 1, 2013. Additional information may be found on the compliance page for SDs and MSPs on the NFA’s website. At this time, SDs and MSPs relying on the Final Exemptive Order Regarding Compliance With Certain Swap Regulations are not required to submit policies and procedures that would otherwise be required by CFTC Regulations 23.502 and 23.504 with respect to trades with non-US counterparties. 

The NFA notice to members is available here. The NFA compliance page is available here.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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