The National Futures Association proposed to increase capital requirements for forex dealer members and to require such members to implement risk management programs, among other initiatives. The measures were proposed by NFA in response to significant losses sustained by some FDMs in January 2015 after the Swiss National Bank unexpectedly removed its cap on the Swiss Franc’s exchange rate against the Euro and the value of the Swiss Franc soared. Under NFA’s proposed rule amendments, FDM capital requirements would account for risks associated with FX transactions between an FDM and so-called “eligible contract participants” (very sophisticated or financially capable natural or non-natural persons), especially those acting as forex dealers; FDMs will be required to collect security deposits from ECP counterparties; and FDMs will be precluded from being a counterparty to an ECP that acts as a dealer, unless the ECP itself collects security deposits from its customers and ECP counterparties equivalent to what the FDM itself must collect. (Currently FDMs are subject to a capital requirement of the higher of US $20 million plus 5 percent of all amounts owed to clients in excess of US $10 million or, if a futures commission merchant, FCM capital requirements.) FDMs will also be required to make certain disclosures on their website on an ongoing basis regarding their business activities, certain material risks, their capital and customer liabilities; pending material regulatory complaints or actions; and other matters. Additionally, FDMs will be required have an annual report prepared by their chief compliance officers that is provided to their senior officer or boards of directors, certified by the CCO or the FDM’s chief executive officer, and filed with NFA. In addition, NFA proposed to adopt an interpretive notice that would require FDMs to implement and enforce a risk management program, including establishing a risk management unit that is independent from employees involved in the sales, trading and promotional activities of the FDM. The risk management program must be reviewed and tested at least annually and upon any material change by the FDM, according to NFA’s proposed interpretive notice.