NFA proposed a new interpretive recognize to NFA
Compliance Rule 2-9(d) (“Supervision”) that
would call for swap dealers (“SDs”) and important swap
participant members (“SD Users”) to build a
supervisory program for the use of internet marketing components. NFA defines
“promoting substance” as a standardized doc utilised to
solicit a counterparty to enter into swap transactions with the SD
Member.
NFA stated that an “satisfactory” supervisory technique have to
include things like prepared policies and strategies for (i) examining and
approving promoting materials, (ii) training workers on
suitable marketing elements, and (iii) recordkeeping.
In addition, NFA mentioned that such application must be “made
to fairly be