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As a reminder, the compliance date for the National Futures Association’s (NFA) Swaps Proficiency Requirements is January 31, 2021. NFA Members with associated persons (AP) required to satisfy NFA's Swaps Proficiency...more
The scheduled implementation date applicable for most financial end users for the mandatory posting of variation margin to their swap dealer counterparties under U.S. margin rules is March 1, 2017. In most cases, the U.S....more
Demonstrating coordination between US swap rules and those of the European Union, the Commodity Futures Trading Commission issued a no action letter (no. 13-45) on July 11 that permits a company organized under the laws of...more
In late June 2013, the Commodity and Futures Trading Commission (CFTC) issued a no-action letter extending the period for certain corporate end-users of foreign exchange (FX) derivative transactions to comply with the trading...more
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...more
Managers Who Use Swaps Should Act Now - Managers of funds and separately managed accounts that use swaps are reminded that they (or their clients) must complete the DF Protocol Adherence Letter and DF Protocol...more