NFA to Require Electronic Filing of Initial Margin Model-related Notices
Commentary by Nihal Patel
NFA notified its members that swap dealers must electronically file required notices related to swap dealer initial margin models.
NFA said that it will no longer accept event notices via email, and it will require member firms subject to CFTC margin requirements to electronically file relevant notices (required pursuant to CFTC Reg. 23.154) using NFA's WinJammer filing system. The change becomes effective on September 1, 2022.
NFA indicated that swap dealer member firms should file the required notices with minimal delays, and firms will be required to update initial notices in the event of material changes.
Commentary
The notice provides little interpretive gloss on these notice requirements (e.g., what "additional product type" means or what a "material change" to an assumption means), other than saying that notifications are not required in connection with new releases of ISDA SIMM.