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NFA Proposes Amendments to Several NFA Rules and Interpretative Notices to Apply to Cleared Swaps

On December 3, the National Futures Association (NFA) proposed amendments to various NFA Compliance Rules and Interpretive Notices related to discretionary customer accounts, customer information, risk disclosures and bunched orders to apply to cleared swaps, in addition to other minor amendments. Most notably, NFA proposal would amend the following:

  • NFA Compliance Rule 2-8 to specify that NFA’s requirements for discretionary accounts apply to cleared swaps customer accounts;

  • NFA Compliance Rule 2-30 to expand existing customer information and risk disclosure requirements to apply to cleared swaps; and

  • Interpretive Notice 9029 to expand the scope of the Interpretative Notice to bunched orders involving cleared swaps.

NFA also proposed amendments to other applicable Interpretive Notices to integrate the proposal.

Absent additional review by the Commodity Futures Trading Commission (CFTC), NFA may establish an effective date for the amendments as early as 10 days after receipt of the submission by the CFTC.

A copy of the proposed amendments is available here.

©2020 Katten Muchin Rosenman LLP


About this Author

Christian B. Hennion, Finance Attorney, Katten Muchin Law Firm

Christian B. Hennion concentrates his practice in financial services and asset management matters, including counseling fund managers, registered investment advisers and commodity trading advisors on both transactional and regulatory matters. Chris has advised a wide range of US and international managers, from start-ups to large institutions, regarding a variety of matters, including private fund launches and reorganizations, advisory engagements, Investment Advisers Act and Commodity Exchange Act compliance obligations, Securities and Exchange Commission (SEC) and Commodity Futures...

Jack West Financial Attorney Katten

Jack West is an associate in the Financial Markets and Funds practice.