On December 8, the National Futures Association (NFA) issued Notice I-20-45 to remind member firms that the compliance date for NFA’s Swaps Proficiency Requirements (Requirements) is January 31, 2021 (Compliance Date). As more fully discussed in the July 10, 2020 edition of the Corporate & Financial Weekly Digest, NFA Members with associated persons (AP) required to satisfy the Requirements must ensure that covered individuals are in compliance by the Compliance Date. Individuals who do not satisfy the Requirements by the Compliance Date will be unable to engage in swaps activities until they have done so. After the Compliance Date, any individual seeking to engage in swaps activity will need to satisfy the Requirements prior to being approved as a swap AP at an intermediary or acting as an AP at a swap dealer.

For complete details regarding who must fulfill the Requirements, Notice I-19-09 is available here.

Notice I-20-45 is available here.