As we have previously discussed,[1] “associated persons” of National Futures Association members that engage in swaps-related activities will be required to satisfy new swaps proficiency requirements. Covered NFA members (including a large number of hedge fund managers) will also be required to designate a “Swaps Proficiency Requirements Administrator” to track compliance with these new requirements. The registration portal for this function will open Nov. 1, 2019.

To help prepare these internal administrators for their future responsibilities, the NFA has prepared a training webinar that will be made available in three viewing windows:

  • Wednesday, Oct. 23, 2019 at 9:30 am CT/10:30 am ET[2]
  • Thursday, Nov. 7, 2019 at 8:30 am CT/9:30 am ET[3]
  • Tuesday, Dec. 10, 2019 at 9:30 am CT/10:30 am ET[4]

Every hedge fund manager that (i) is registered with the NFA as a commodity pool operator and (ii) engages in swaps-related activity should assess whether their associated persons will be captured by the new requirements and, if so, should appoint a Swaps Proficiency Requirements Administrator and have that person attend one of these web-based trainings.

In addition, these hedge fund managers (i.e., commodity pool operators that are NFA members and are approved as “swaps firms”) will be subject to an annual dues surcharge of $1,750.[5]