Pursuant to Commodity Futures Trading Commission No-Action Letter No. 13-40, swap dealers (SDs) and major swap participants (MSPs) are required to comply with the portfolio reconciliation requirements in CFTC Regulation 23.502 as of August 23, 2013. The National Futures Association (NFA) issued a notice to remind SDs and MSPs to submit policies and procedures relating to such requirements no later than August 23. SDs and MSPs should make the required submissions through the NFA’s Registration Documentation Submission System, which can be accessed here.

SDs and MSPs relying on the CFTC’s Interpretive Guidance and Policy Statement Regarding Compliance with Certain Swap Regulations are not required to submit policies and procedures relating to such portfolio reconciliation requirements for trades with non-US counterparties. 

The NFA’s Notice I-13-21 is available here.