ARTICLE
2 December 2021

NFA Proposes Amendments To Financial Reporting Requirements For SEC-Registered SDs

CW
Cadwalader, Wickersham & Taft LLP

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NFA proposed amendments to its financial reporting requirements for swap dealers ("SDs") that are also subject to SEC financial reporting requirements.
United States Finance and Banking
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NFA proposed amendments to its financial reporting requirements for swap dealers ("SDs") that are also subject to SEC financial reporting requirements.

NFA said that the proposed changes to the Financial Requirements in Section 18(e) ("Financial Reporting") are intended to reflect that certain SDs that are also SEC registrants may rely on SEC Rule 18a-10 ("Alternative compliance mechanism for security-based swap dealers that are registered as swap dealers and have limited security-based swap activities") and not be subject to SEC capital and financial reporting requirements.

Barring a CFTC review determination, the proposed amendments will go into effect 10 days following the CFTC's receipt of the submission.

Primary Sources

  1. NFA Rule Submission: Proposed Amendments to NFA Financial Requirements Section 18 Swap Dealer and Major Swap Participant Financial Requirements

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