ARTICLE
28 September 2021

Effective Date Set For NFA Amendments To Compliance Rule On Swap Dealer Trade Execution

CW
Cadwalader, Wickersham & Taft LLP

Contributor

Cadwalader, established in 1792, serves a diverse client base, including many of the world's leading financial institutions, funds and corporations. With offices in the United States and Europe, Cadwalader offers legal representation in antitrust, banking, corporate finance, corporate governance, executive compensation, financial restructuring, intellectual property, litigation, mergers and acquisitions, private equity, private wealth, real estate, regulation, securitization, structured finance, tax and white collar defense.
NFA amendments to Compliance Rule 2-49 regarding trade execution requirements by member swap dealers will go into effect on September 30, 2021.
United States Finance and Banking
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NFA amendments to Compliance Rule 2-49 ("Swap Dealers and Major Swap Participants Regulations") regarding trade execution requirements by member swap dealers will go into effect on September 30, 2021.

As previously covered, the amendments clarify that a violation of the trade execution requirements of CFTC Rule 37.12 ("Trade Execution Compliance Schedule") or CFTC Rules Part 50 ("Clearing Requirement and Related Rules") of the CFTC's rules also constitutes a violation of an NFA requirement.

Primary Sources

  1. NFA Notice I-21-32: Effective date for amendments regarding mandatory clearing and trade execution requirements for SDs

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