National Futures Association (NFA) has revised its review process for swap dealer (SD) and major swap participant (MSP) applications under Section 4s of the Commodity Exchange Act. Effective immediately, SDs and MSPs are no longer required to submit additional documentation or revisions in response to NFA’s feedback letters. (As background, NFA issues a feedback letter to an SD or MSP after it has conducted a detailed review of the firm’s Section 4s submission.)
SDs and MSPs now are required to submit an attestation signed by the firm principal that attests that the firm has revised its policies and procedures to address the issues raised in the feedback letter. For firms with active feedback letters, NFA will reissue feedback letters identifying where an attestation is required to be submitted instead of revised documentation.
More information is available here.