NFA Update

New proficiency requirements for hedge fund managers

Brian T. Daly and Joshua B. Wright, Schulte Roth & Zabel
Originally published in the April | May 2019 issue

The National Futures Association, the self-regulatory organization for the commodity futures and swaps industry, recently updated its rules1 to impose “swaps proficiency requirements” on associated persons of NFA members that engage in swaps-related activities. These requirements are likely to be applicable to a significant number of hedge fund advisers (i.e., advisers that are, or are required to be, registered with the Commodity Futures Trading Commission and to be NFA members). While most private equity sponsors are not likely to fall within the scope of any NFA licensing requirement, they should take this opportunity to confirm that the basis for any exemption remains valid. 

Effective dates

Compliance with the new NFA swaps proficiency requirements will be required as of Jan. 31, 2021, and online access to the new training modules is targeted for Jan. 31, 2020. 


A fee schedule for completing the swaps proficiency requirements has not yet been published.

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