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Brief
On March 20, 2025, the Commodity Futures Trading Commission (CFTC) issued an update regarding CFTC Staff Issues Interpretation Regarding Financial Reporting Requirements for Japanese Nonbank Swap Dealers. The interpretation clarifies that Japanese nonbank SDs can satisfy a condition of the CFTC's comparability order by filing certain schedules from their Annual Business Report with the CFTC and the National Futures Association (NFA), subject to translation, dollar conversion, and deadline requirements.
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