The National Futures Association (“NFA”) recently amended NFA Bylaw 301 and NFA Compliance Rule 2-24 and adopted an interpretive notice to implement new swaps proficiency requirements. All associated persons (“APs”) of commodity pool operators (“CPOs”), commodity trading advisors (“CTAs”) and certain other Commodity Futures Trading Commission registrants must complete the swaps proficiency requirements if such persons engage in swaps activity.

An individual can begin satisfying these requirements on January 31, 2020, and must have completed the requirements no later than January 31, 2021. The swaps proficiency requirements consist of training and testing, both of which will be administered online. The NFA estimates that APs of CPOs and CTAs will be able to complete the swaps proficiency requirements in four hours.