NFA Regulatory Notice: July 2013 Revisions for FCMs, IBs, CPOs and CTAs
The NFA released July 2013 revisions to the Financial Requirements Section 16 and the related interpretive notice regarding cleared swaps customer collateral accounts. These updates are available in five appendices of policies that include:
- Compliance with theExchange Act Rule 15c3-1: the calculation of haircut charges on securities; additionally, charges on the more common securities are reviewed: government securities and Canadian debt obligations, municipal securities, other municipal securities, money market funds, commercial paper, bankers' acceptances and certificates of deposit, non-convertible debt securities, convertible debt securities, common stock, and preferred stock;
- The NFA Anti-Money Laundering Questionnaire supplementing the NFA compliance rule in FCM and IB anti-money laundering programs, as each Member firm must adopt a written anti-money laundering ("AML") program specific to its operations in the following areas: general, customer identification program ("CIP"), identifying high-risk accounts, suspicious activity, and other areas;
- The NFA Business Continuity and Disaster Recovery Plan Questionnaire supplementing the NFA compliance rule in a business continuity and disaster recovery plan to help Member firms adopt a written business continuity and disaster recovery plan specific to their operations, implementable, and communicated to the Member firms' employees;
- The NFA Ethics Training Policy Questionnaire supplementing the NFA compliance rule in ethics training requirements to help Member firms adopt an ethics training policy that is specific to their operations, implementable, and communicated to the Member firms' employees; and
- The NFA Privacy Policy Questionnaire aiding support in meeting the Member firms' obligations under the CFTC's privacy rules.