News & Analysis as of

Swap Dealers Recordkeeping Requirements National Futures Association

Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own... more +
Swap Dealers are individuals or entities who "hold themselves out as dealers in swaps, make markets in swaps, regularly enter into swaps with counterparties as an ordinary course of business for its own account, or engage in any activity causing the individual or entity to be come commonly known in the trade as a dealer or market maker of swaps." Swap Dealers are defined under the Commodity and Exchange Act and must register as such under the Commodity Futures Trading Commission's Final Rules.  less -
A&O Shearman

National Futures Association Simplifies Section 4s Submission and Review Process for Swap Dealer Registration

A&O Shearman on

On July 24, 2017, the National Futures Association (“NFA”) adopted measures to streamline the process for registration of swap dealers pursuant to Section 4s of the Commodity Exchange Act. Previously, entities seeking to...more

Katten Muchin Rosenman LLP

Bridging the Week - March 2016 #3

Industry Comments to Regulation AT Argue CFTC Proposed Rules Too Prescriptive; Registration and Source Code Requirements Particularly Objectionable - After declining multiple requests to extend the comment period that...more

Dechert LLP

NFA Adopts Cybersecurity Guidance

Dechert LLP on

The National Futures Association (NFA) adopted on October 23, 2015 an “Interpretive Notice to NFA Compliance Rules 2-9, 2-36, and 2-49: Information Systems Security Programs” (Notice). The Notice requires each NFA Member to...more

Foley Hoag LLP - Security, Privacy and the...

CFTC Approves NFA Interpretive Notice on Information Systems Security Programs, Including Cybersecurity Guidance

The CFTC recently approved the National Futures Association’s interpretive notice (the “Cybersecurity Notice”) on the general requirements that members should implement for their information systems security programs...more

Katten Muchin Rosenman LLP

Corporate and Financial Weekly Digest - August 16, 2013

In this issue: - SEC Issues Risk Alert on Options Trading Used to Evade Short-Sale Requirements - SEC Order Temporarily Exempting Certain Broker Dealers and Certain Transactions from the Recordkeeping and...more

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