A swap dealer agreed to pay $900,000 to settle National Futures Association ("NFA") charges relating to initial margin for uncleared swaps. The NFA alleged that the firm used insufficient methods to evaluate the risks of its uncleared swaps and failed to appropriately back test, benchmark and verify its margin model. The NFA alleged that the swap dealer (i) neglected to take the necessary steps to meet the initial margin and variation margin collection requirements, (ii) failed to adequately supervise its business activities with respect to margin and model monitoring, and (iii) submitted inaccurate information in reports to the NFA. The swap dealer neither admitted to nor denied the NFA's findings.
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