NFA SWAPS PROFICIENCY REQUIREMENTS MUST BE COMPLETED BY JANUARY 31, 2021 - 22 July 2020

Reminder, NFA’s Swap Proficiency Requirements must be successfully completed by individuals registered as APs at FCMs, IBs, CPO and CTAs who engage in swaps activity subject to the CFTC’s jurisdiction as well as individuals acting as APs at swaps dealers. Individuals approved as swap APs on January 31, 2021 (the “Compliance Date”), must have satisfied the Swaps Proficiency Requirements to remain approved as a swap AP after the Compliance Date.  Individuals who do not satisfy the proficiency requirements by the Compliance Date will not be able to act as a swap AP until NFA’s Swap Proficiency Requirements have been satisfied.

NFA Members with swap APs are required to designate an individual or individuals who will coordinate Swaps Proficiency Requirements enrollment and track progress (a “SPR Admin”). In order to qualify as an SPR Admin, a person must be an ORS Security Manager for the Member.  Designate a SPR Admin by completing the Swaps Proficiency Requirements Administrator Form. 

SPR Admins are responsible for submitting and/or coordinating a swap APs enrollment for the Swaps Proficiency Requirements. The NFA will email the swap AP login information to access the NFA’s Swaps Proficiency Requirements. Swap APs not associated with an NFA Member firm can enroll online.   The NFA has made available additional information and guidance regarding the Swaps Proficiency Requirements .

NFA's Swaps Proficiency Requirements have two tracks: the Long Track and the Short Track. Each Track is module based and contains both a learning component and a testing component.    

The Long Track consists of eight modules and a total of 100 test questions:

• Swap Products and Applications (20 test questions)
• Regulation of the Swaps Market (20 test questions)
• Onboarding (10 test questions)
• Transactional Disclosures (10 test questions)
• Anti-Fraud and Ethical Practices (10 test questions)
• Trade Execution/Clearing/Margin (10 test questions)
• Risk Management (10 test questions)
• Supervision (10 test questions)

 The Short Track consists of four modules and a total of 60 test questions: 

• Swaps Products and Applications (20 test questions)
• Regulation of the Swaps Market (20 test questions)
• Supervision (10 test questions)
• Compliance, Anti-Fraud, and Other Requirements (10 test questions)

The Long Track is primarily designed for individuals acting as APs at swap dealers. The Short Track is primarily designed for APs at FCMs, IBs, CPOs or CTA. The NFA estimates the Long Track can be completed in approximately 8 hours and the Short Track can be completed in approximately 4 hours.

The testing component of the modules is based solely on the content presented in the modules' learning component.  Therefore, there is no need for additional training or study guides to complete NFA's Swaps Proficiency Requirements. 

NFA amended Bylaw 301 and Compliance Rule 2-24 and adopted Interpretive Notice entitled NFA Bylaw 301 and Compliance Rule 2-24: Proficiency Requirements for Swap APs to implement NFA’s Swap Proficiency Requirement.  NFA Bylaw 301(l) was amended to specify that any individual seeking approval as an FCM, IB, CPO or CTA Member swap form or as a swap AP must take and pass the NFA’s Swap Proficiency Requirements.  NFA Compliance Rule 2-24 was amended to prohibit an FCM, IB, CPO or CTA Member from having any person engaging in CFTC regulated swaps associated with it that has not satisfied NFA’s Swap Proficiency Requirements.