United States: Effective Date Set For NFA Late Fee Amendment And Interpretive Notice On Certain IM Model-Related Filings

An NFA interpretive notice on swap dealer reporting requirements, and the imposition of a late filing fee of $1,000 per business day for certain reports, will go into effect on October 6, 2021.

As previously covered, the interpretive notice would clarify swap dealer reporting requirements with respect to initial margin model performance. The late fee would apply to "each financial report or other filing" required under NFA Financial Requirements Section 17 ("Swap Dealer and Major Swap Participant Reporting Requirements") (as well as reports under Sections 1, 5, 6, 11 and 18).

Primary Sources

1. NFA Notice I-21-30: Effective date for amendment imposing a late fee for certain SD filings and new Interpretive Notice clarifying existing SD filing requirements

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