The CFTC staff determined (pursuant to delegated authority) that NFA's swap dealer capital model requirements and review process "are comparable" to CFTC requirements and processes.

CFTC Rule 23.102 ("Calculation of Market Risk Exposure Requirement and Credit Risk Exposure Requirement Using Internal Models") permits a swap dealer "to apply to the CFTC, or to a registered futures association, to obtain approval to use internal market risk and/or credit risk models in computing the swap dealer's regulatory capital."

The CFTC staff found "no material differences" between the agencies' model approvals, thereby allowing NFA approval to function as an alternative means of compliance with CFTC Rule 23.102.


It was generally anticipated that the CFTC would delegate review of firms' capital models to NFA.

Primary Sources

  1. CFTC Letter 21-03: Swap Dealer Capital Model Determination Letter
  2. CFTC Press Release: CFTC Approves NFA's Swap Dealer Capital Model Review Program

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