The DFA questionnaire is encapsulated in a KYC Type available in the Due Diligence stage. It has four item groups:
- DFA Cross-Border Representation Letter
- Firm and counterparty classification
- Special Entities
- Institution suitability
‘DFA Cross-Border Representation Letter’ is the item group where the data contained in the DFA Cross-Border Representation Letter, if collected, is entered in the application.
The goal of the CBRL is to ascertain whether the customer has a US connection that would make it a "U.S. Person" according to the definition of CFTC.
‘Firm and counterparty classification’ is where, amongst other things, the customer is classified as either Major Swap Participant (MSP), Swap Dealer (SD), or Non-SD/MSP.
For MSP and SD customers, the classification is the steppingstone from which other DFA requirements derive, like capital, margin, reporting, recordkeeping, and operational requirements.
‘Special Entities’ is the item group where information is collected on customers which fall under the definition of “Special Entity”, as there are additional duties to be satisfied when the CP is classified as such.
‘Institutional suitability’ is the item group focusing on to determining whether the CP or its agent is capable of evaluating independently the risks of the swap or the trading strategy.