Portfolio Reconciliation and Swap Trading Relationship Documentation Requirements Approaching

June 30, 2013 is the compliance date for the portfolio reconciliation and swap trading relationship documentation requirements set forth in CFTC Rules 23.502 ("Portfolio reconciliation") and 23.504 ("Swap trading relationship documentation"). Accordingly, provisionally registered swap dealers ("SDs") and major swap participants ("MSPs") are required to submit policies and procedures relating to those requirements no later than Monday, July 1, 2013 (but the NFA cautioned that earlier would be better). Registrants are not required to submit policies and procedures with respect to trades with non-U.S. counterparties at this time.

See: NFA Notice I-13-17.