Swaps Proficiency Requirements FAQs

The following individuals must satisfy NFA's Swaps Proficiency Requirements prior to engaging in swaps activity:

• Any individual registered or seeking registration as an associated person (AP) of a futures commission merchant (FCM), introducing broker (IB), commodity pool operator (CPO) or commodity trading advisor (CTA) who intends to engage in swaps activity subject to the CFTC's jurisdiction.
• With the exception of certain individuals who seek to act as AP at swap dealers (SDs) in non-U.S. jurisdictions (as noted in the chart below), any individual who seeks to act as an AP at an SD as defined by the CFTC in subsection 6 of the Associated Person definition under CFTC Regulation 1.3. NFA's Swaps Proficiency Requirements in no manner alter this definition.

Other than the exception for certain individuals acting as associated persons at SDs in non-U.S. jurisdictions, NFA is not providing relief from the Swaps Proficiency Requirements to any other individuals, including individuals granted relief from NFA’s other proficiency requirements under NFA Registration Rule 402.

The chart below shows the applicability of NFA's Swaps Proficiency Requirements to individuals seeking to act as APs at SDs based on the SD's location and type of counterparty. As shown in the chart below, NFA's Swaps Proficiency Requirements individuals seeking to act as APs at SDs in non-U.S. jurisdictions (including non-U.S. based branch offices of a U.S. SD) in specified circumstances.

An individual seeking to act as an AP at a swap dealer who will engage in swaps transactions with a Category A counterparty must satisfy NFA's Swaps Proficiency Requirements regardless of whether the individual will also engage in swaps transactions with counterparties from Categories B, C or D.

For example, an individual seeking to act as an AP at a non-U.S. branch of a U.S. SD who will only engage in swaps transactions with other non-U.S. branches of U.S. SDs is not required to satisfy NFA's Swaps Proficiency Requirements. However, if that individual will also engage in swaps transactions with a U.S. person (excluding a non-U.S. branch of a U.S. SD), then that individual is required to satisfy NFA's Swaps Proficiency Requirements before acting as an AP.

Individuals seeking to act as APs of non-U.S. SDs (including non-U.S. SDs that are affiliates of a U.S. person) whose counterparties will be limited to non-U.S. branches of U.S. SDs and non-U.S. persons are not required to satisfy NFA's Swaps Proficiency Requirements.

NFA's Swaps Proficiency Requirements have two tracks: the Long Track and the Short Track. Each Track is module based and contains both a learning component and a testing component.

The Long Track consists of eight modules and a total of 100 test questions:

• Swap Products and Applications (20 test questions)
• Regulation of the Swaps Market (20 test questions)
• Onboarding (10 test questions)
• Transactional Disclosures (10 test questions)
• Anti-Fraud and Ethical Practices (10 test questions)
• Trade Execution/Clearing/Margin (10 test questions)
• Risk Management (10 test questions)
• Supervision (10 test questions)

The Short Track consists of four modules and a total of 60 test questions:

• Swaps Products and Applications (20 test questions)
• Regulation of the Swaps Market (20 test questions)
• Supervision (10 test questions)
• Compliance, Anti-Fraud, and Other Requirements (10 test questions)

The testing component of the modules is based solely on the content presented in the modules' learning component. Therefore, there is no need for additional training or study guides to complete NFA's Swaps Proficiency Requirements.

Individuals Acting as APs at SDs

In general, SDs must ensure that individuals acting as APs satisfy the Long Track. SDs must also ensure that individuals responsible for supervising individuals acting in the capacity of APs satisfy the Long Track.

Some SDs have designated as APs individuals who are not in the SD's sales and trading areas and who do not negotiate, price and/or execute swaps with counterparties on behalf of the SD or manage the SD's swaps-related risks (sales and trading activities). For these individuals designated as APs, the SD has the option of requiring the individual to satisfy the Long Track or the Short Track. Similarly, for individuals supervising persons designated as APs but engaged in activities that do not involve sales and trading activities, the SD has the option of requiring those supervising individuals to take the Long Track or the Short Track.

Swap APs at Intermediary Firms – FCMs, IBs, CPOs an CTAs

Individuals approved as or applying for approval as an FCM, IB, CPO or CTA Member swap firm or swap associated person of an FCM, IB, CPO or CTA Member (intermediary swap AP) are required to satisfy the Short Track.

An intermediary swap AP or AP of an SD (collectively, swap AP) who successfully completes the Short Track and moves into a role requiring completion of the Long Track may satisfy NFA's Swaps Proficiency Requirements by completing the remaining modules of the Long Track. Swap APs who have successfully completed the Short Track and wish to satisfy the Long Track should ask their firm to contact NFA's Information Center 312-781-1410 or 800-621-3570 or information@nfa.futures.org).

An AP of an SD who is also an intermediary swap AP must successfully complete the Long Track in order to satisfy NFA's Swaps Proficiency Requirements if the SD requires that the individual satisfy the Long Track.

A swap AP who satisfies the Long Track and then transfers to a role that only requires the Short Track will be deemed to have satisfied the Swaps Proficiency Requirements.

An individual will not have to satisfy NFA's Swaps Proficiency Requirements again, provided the Track previously completed satisfies the Track required by the individual's new position and, since the date the individual satisfied NFA's Swaps Proficiency Requirements, there has been no two-year period during which the individual was not employed by an NFA Member SD (or its affiliated entity) or approved as a swap AP at an intermediary swap firm.

If the individual satisfies the condition described above but previously satisfied the Short Track and will be acting in a capacity that requires that the individual satisfy the Long Track, the individual will only need to take and pass the remaining modules of the Long Track.

Individuals seeking approval as an FCM, IB, CPO or CTA Member swap firm or a swap associated person of an FCM, IB, CPO or CTA Member following employment with an NFA Member SD (or its affiliated entity) must submit an attestation to NFA verifying that there has been no period of two consecutive years during which the individual was not employed by an SD Member (or its affiliated entity).  The attestation is available here and should be returned to NFA at Proficiency@nfa.futures.org.

NFA's Swaps Proficiency Requirements are administered online. Individuals will not be required to travel to a separate testing location. Firms should ensure that their employees are able to access the following website to take the Swaps Proficiency Requirements: https://nfa-swaps-proficiency-requirements.moonami.com.

NFA estimates that the Long Track can be completed in approximately eight hours and the Short Track in approximately four hours. APs will be required to go through the learning component and then pass the testing component for each module. There is no time limit to complete each module. You may exit and re-enter the training or testing component of NFA's Swaps Proficiency Requirements at any time and the system will automatically save your progress. Your progress will also be saved if you are logged out by the system due to a period of inactivity. Once you begin the test component you may not reenter the learning component. Your firm will be able to track your progress through NFA's Online Registration System (ORS).

While individuals are not required by NFA to complete the entirety of the Swaps Proficiency Requirements at one time, all modules (both the learning and testing components) must be successfully completed prior to engaging in activities that require designation as an AP at an SD Member or being approved as a swap AP at an FCM, IB, CPO or CTA Member.

Individuals Associated with an NFA Member Firm

There is no fee to enroll in NFA's Swaps Proficiency Requirements for individuals associated with an NFA Member SD or swap-approved FCM, IB, CPO or CTA. The cost of enrollment in NFA's Swaps Proficiency Requirements for these individuals is included in annual SD and FCM, IB, CPO and CTA membership dues.

Individuals Not Associated with an NFA Member Firm

Individuals who are not associated with an NFA Member firm but seek to satisfy NFA's Swaps Proficiency Requirements for professional or other reasons are required to pay a fee of $100 to take either the Long Track or the Short Track. Payment can be made using Visa and MasterCard debit or credit cards and American Express and Diner's Club credit cards.

SPR Admins can enroll individuals in NFA's Swaps Proficiency Requirements by uploading a file containing specific information about the individuals to the Swaps Proficiency Requirements System. To avoid reporting discrepancies, SPR Admins should enroll individuals using each individual's full legal name. More information is available at the NFA Swaps Proficiency Requirements Administrators webpage.

Individuals affiliated with an NFA Member firm should contact appropriate personnel at their firm. Individuals not affiliated with an NFA Member firm should contact NFA's Information Center (312-781-1410 or 800-621-3570 or information@nfa.futures.org).

SPR Admins should contact NFA's Information Center (312-781-1410 or 800-621-3570 | information@nfa.futures.org) to correct an individual’s track. SPR Admins should be able to readily provide the username and email of the individual as well as the track the individual is currently enrolled in and the track the individual needs to be enrolled in to ensure that NFA can make the appropriate changes. SPR Admins are able to edit most information about an individual without assistance from NFA, but must contact NFA to change an individual’s track or remove an individual from enrollment in the Swaps Proficiency Requirements.

Individuals must achieve a score of 70 percent or greater on each module within the individual's assigned/chosen track in order to receive a Certificate of Completion.

Authorized ORS users can track the progress of their employees in ORS using the Individual Status by Firm Report.

A Member firm's authorized ORS users may also verify an individual's proficiency status in ORS using Completion Date by Individual Report. If the individual is a registered swap AP, authorized ORS users can also confirm the individual's status in the Proficiency Information section of ORS. Discrepancies between a registered swap AP's name as it appears in ORS and how it is entered by the SPR Admin during enrollment may result in an AP's proficiency status being inaccurately reflected in ORS. SPR Admins should check the proficiency status of their registered swap APs in ORS to ensure that it is accurate. SPR Admins who identify a registered swap AP who has satisfied the Swaps Proficiency Requirements but the AP's proficiency status is not reflected in the AP's ORS record should contact NFA's Information Center (312-781-1410 or 800-621-3570 | information@nfa.futures.org) .

The proficiency status of individuals who are registered APs and NFA Associate Members may also be verified by checking their history in BASIC. Designation as a swap AP as displayed in the history timeline in BASIC will indicate successful completion of the Swaps Proficiency Requirements.

When you access NFA's Swaps Proficiency Requirements, we request personal information from you necessary to verify your identity, to maintain the accuracy of NFA's records, and to provide Member-facing and/or public-facing information about you and your completion of the Swaps Proficiency Requirements. Although not required to access NFA's Swaps Proficiency Requirements, the furnishing of the last four digits of a social security number assists NFA in identifying individuals who have completed them.

The following types of personal information are collected from individuals accessing the Swaps Proficiency Requirements:

• Name
• Email address
• Last four digits of social security number (optional)
• Date of birth
• NFA ID (if applicable)

If an individual transfers to a different Member firm after enrolling but before beginning the Swaps Proficiency Requirements, the individual should re-enroll in the Swaps Proficiency Requirements at his or her new firm. The SPR Admin at the firm from which the individual transferred is encouraged to delete that individual from their firm reports by clicking on the red "X" next to the individual's name on the "Individuals Affiliated with my Firm" list in ORS. SPR Admins may also submit a request to NFA's Information Center (312-781-1410 or 800-621-3570 | information@nfa.futures.org) to delete the individual from their firm reports. 

If an individual transfers to a different Member firm after completing only part of the Swaps Proficiency Requirements, the SPR Admin at the individual's new firm should submit a request to NFA's Information Center (312-781-1410 or 800-621-3570 | information@nfa.futures.org) to transfer that individual's Swaps Proficiency Requirements enrollment to the new firm. The request should include the following information: the individual's first and last name, the individual's email address at the previous firm, the individual's email address at new firm, the full name and firm ID of the new firm and the individual's new username if it will be different from the individual's new email address. The SPR Admin at the firm from which the individual transferred is encouraged to delete that individual from their firm reports as described above.

If an individual transfers to a different Member firm after completing the Swaps Proficiency Requirements, the SPR admin at the individual's new firm may obtain proof of the individual's completion by clicking the push pin icon next to the individual's name in the ORS Completion Date by Individual Report.  This ensures that the individual will appear in the firm's future reporting.  SPR Admins may also submit a request to NFA's Information Center (312-781-1410 or 800-621-3570 | information@nfa.futures.org) to request a copy of the individual's certificate of completion from NFA.  The SPR Admin at the firm from which the individual transferred is encouraged to delete that individual from their firm reports as described above.