ARTICLE
11 October 2017

NFA Provides Guidance On Swap Valuation Dispute Filing Requirements

CW
Cadwalader, Wickersham & Taft LLP

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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.
The National Futures Association ("NFA") notified members of forthcoming changes regarding swap valuation dispute notices and monthly swap dealer ("SD") risk data reports.
United States Finance and Banking
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The National Futures Association ("NFA") notified members of forthcoming changes regarding swap valuation dispute notices and monthly swap dealer ("SD") risk data reports.

The NFA is responsible for handling swap valuation dispute notices filed by SDs under CFTC Rule 23.502(c). Through an Interpretive Notice to NFA Compliance Rule 2-49, the NFA outlined (i) the types of valuation disputes that SDs must report and (ii) standardized data that SDs must provide with each valuation dispute report (see previous coverage).

As part of its efforts to ensure the effective oversight of SDs, the NFA also requires SDs to submit monthly risk data reports that include specific metrics. These reports are intended to help the NFA recognize firms that present significant risk. SDs must submit the first such report by January 31, 2018.

The NFA will hold a webinar to educate industry members on the filing requirements on October 12, 2018. Interested parties can register here.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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