NFA – Proposed Amendments to NFA Financial Requirements Section 10 to Impose Late Fee for Certain Swap Dealer Filings and Proposed Interpretive Notice entitled Financial Requirements Section 17: Initial Margin Model Ongoing Monitoring Reports

August 23, 2021SD Late Fees: Amended Section 10 of financial requirements to impose late fee for certain SD filings. Added filings required by NFA Financial Requirements S.17 to items assessed late fee. Section 17 required each SD and each major swap participant member to file financial, operational, risk management and other required information, as prescribed by NFA.

Initial Margin Model: Proposed new interpretive notice on initial margin model ongoing monitoring reports. Clarified the reporting requirements for SD members related to IM model performance. Specified currently required data, made clear expectations on quarterly/annual filings.

Effectiveness: 10-day provision invoked, amendments effective as early as ten days after submission.

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