By: Josh Johnson

In March 2019, National Futures Association (NFA) announced that all swap Associated Persons (APs) would be required to complete a new swaps proficiency requirement by January 31, 2021. As swap firms are aware, the initial registration process was completed by NFA earlier this year to setup a swap administrator for all firms and also list any APs that would be required to take the proficiency test. Recently, we received feedback from Turnkey Trading Partners (Turnkey) clients regarding the actual proficiency tests and the amount of time an AP can expect to spend completing this requirement. Below we will provide an outline and overview of the Short Track that is required for a swap AP of any swap Futures Commission Merchant (FCM), Introducing Broker (IB), Commodity Trading Advisor (CTA) or Commodity Pool Operator (CPO).

Short Track Overview

The Short Track is broken up into four different sections. Unlike the Series 3, this test includes a module that is required to be reviewed and provides the information that will subsequently be tested. This setup is similar to what firms would offer when completing the various trainings; Ethics, AML, Cybersecurity.

First Section: Swaps Products and Applications

This section is a general overview of swaps. It is setup to take approximately two hours to complete and includes a 20-question test at the end that the user must pass to move onto the subsequent sections. It should be noted that all tests are multiple choice or true/false questions and there does not appear to be any need to complete any calculations, unlike the Series 3.

Second Section: Regulation of the Swaps Market

An overview of the rules and regulations that govern the swaps markets. This section is shown as taking 90 minutes and again includes a 20-question test that must be passed.

Third Section: Supervision

An overview of the supervisory requirements for swap firms and supervisory APs. This section is slated to take approximately 30 minutes and includes a 10-question test at completion.

Final Section: Compliance, Anti-Fraud and Other Requirements

A catchall section that includes an overview of other items deemed important for review. The final section is scheduled to take approximately one hour and includes a 10-question test.

In all the four sections should take a user approximately five hours to complete, and potentially a bit less depending on the individual. The four sections include a total of 60 questions, and each section requires a passing percentage of 70%. For APs of Swap Dealers (SD) the Long Track consists of eight sections with a total of 100 questions. From the NFA website it would appear this should take an individual 8-10 hours to complete.

Turnkey Trading Partners is happy to assist any swap firms as they ensure all necessary individuals complete the swap proficiency requirements or any other compliance obligations required. Please contact us today to learn more. We can be reached via phone at (312) 324-0040 or via email by using

About the author:

Josh Johnson has over ten years of experience working with regulatory and compliance matters within the financial services industry.  Prior to joining Turnkey, Josh worked at National Futures Association (NFA) in various roles where he led numerous reviews of NFA member firms. Additionally, Josh worked in the internal audit department at State Street Corporation conducting reviews of the various business units and offerings of the bank. Josh has a degree in finance from the University of Iowa.