4s Process and Due Dates

The CFTC's swap dealer (SD) registration rules require, among other things, that in order to become registered, SDs must demonstrate compliance with multiple substantive regulatory requirements (Section 4s Implementing Regulations).

Section 4s Implementing Regulation Submission Process

An SD will become registered upon filing:

• Form 7-R;
• Forms 8-R and fingerprint cards for each of its principals; and
• Documentation attesting to compliance with the applicable Section 4s Implementing Regulation(s).

NFA issues requests to prospective SD registrants through NFA's EasyFile Registration Documentation Submission System (RDSS). Each request requires the prospective SD registrant to submit a written attestation stating that it has adopted written policies and procedures or other appropriate documentation reasonably designed to ensure its SD compliance with the applicable Section 4s Implementing Regulation(s).

SD Members may request confidential treatment of Section 4s Implementing Regulations submissions that are filed with NFA.

Please note: for the Risk Management 4s topic area, new SD applicants will be required to submit both an attestation and its risk management policies and procedures as required by CFTC Regulation 23.600(b)(4).

For SDs with active 4s filings that have received NFA Feedback Letters and have not received an Acknowledgment Letter, the SD should follow the instructions in the Feedback Letter.