NFA Member Notice I-13-19: Compliance Deadlines Deferred on Swap Trading and Portfolio Reconciliation Documentation
The CFTC Interim Final Rule, dated December 18, 2012, deferred the compliance deadline for the portfolio reconciliation and swap trading relationship documentation requirements, set out in Commission Regulations 23.502 ("Portfolio Reconciliation") and 23.504 ("Swap Trading Relationship Documentation"), to July 1, 2013. The CFTC issued Letter No. 13-40, further extending the deadline that SDs and MSPs have to submit portfolio reconciliation proposals pursuant to 23.502, from July 1, 2013 to August 23, 2013. This does not, however, alter the swap trading relationship documentation requirements of Commission Regulation 23.504, also set forth in the rule.