CFTC Approves NFA’s Swap Dealer Model Review Process: CFTC Issues Letter Authorizing the NFA’s Review Process for Approving Swap Dealer Internal Models

Sullivan & Cromwell LLP - January 22, 2021
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On January 12, the Market Participants Division of the CFTC issued a letter approving the NFA’s swap dealer capital model requirements and review program. The MPD staff concluded that the NFA’s model requirements and review process are comparable to those of the CFTC. Accordingly, swap dealers can obtain approval from either the CFTC or the NFA for internal models to be used in computing their regulatory capital under the CFTC’s rules.

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