NFA Proposes Interpretive Notice On Certain IM Model-Related Filings

NFA proposed (i) an interpretive notice to clarify swap dealer reporting requirements with respect to initial margin ("IM") model performance and (ii) the imposition of a late fee of $1,000 per business day if filings, including those related to IM model performance, are late.

NFA said that the late fee would apply to "each financial report or other filing" required under NFA Financial Requirements Section 17 ("Swap Dealer and Major Swap Participant Reporting Requirements") (as well as reports under Sections 1, 5, 6, 11 and 18).

Barring further review by the CFTC, the proposed amendment and related interpretive notice will go into effect 10 days after it is received by the CFTC.