Introduction -

Both the Commodity Futures Trading Commission (CFTC) and the National Futures Association (NFA), the self-regulatory organization for the US derivatives industry, have signaled their expectation—now nearly four years after swap dealers first became provisionally registered—that firms have had sufficient time to implement fully the CFTC’s swap regulations. This alert updates recent changes in NFA’s approval process, provides a status report on NFA’s current examination schedule and previews what changes swap dealers may expect in future NFA examinations.