Nomura Global Financial Products Inc.

World Wide Plaza

309 West 49th Street

New York, NY 10019-7316

(212)667-9300 www.nomura.com

FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO 5 U.S.C. § 552 AND 17 CFR § 145.

Mr. Thomas Smith 24 September 2021

Deputy Director, Capital, Margin & Segregation

Commodity Futures Trading Commission

Three Lafayette Centre

1155 21st Street, NW

Washington, DC 20581

cc: Alessandra Riccardi, National Futures Association

Dear Mr. Smith:

Nomura Global Financial Products Inc. (“NGFP” or “Firm”) hereby requests a time limited No 

Action Relief from regulation 23.102(f)(1) wherebyNGFP calculates its credit risk charges using 

internal models that have not been approved for use by the Commission, the National Futures 

Association (“NFA”), the Securities and Exchange Commission (“SEC”), a prudential regulator, or 

a foreign regulatory authority in lieu of the standardized credit risk charges required under 

regulation 23.103(b). NGFP requests this relief for a time-limited basis not to exceed November 

1, 2021.

In addition, NGFP requests to amend its election pursuant to CFTC Rule 23.102(f) for the use of 

internal model(s) approved by another qualified regulator, Japanese Financial Services Agency

(JFSA), to calculate market risk exposures as authorized in CFTC Rule 23.102(f)(1). 

Background

NGFP is provisionally registered with the CFTC as a Swap Dealer (“SD”), the SEC as an 

Over-the-CounterDerivatives Dealer (“OTC DD”) and intends to register with the SEC as a nonbank Security-Based Swap Dealer (“SBSD”) on November 1, 2021. NGFP is also a subsidiary of 

Nomura Holdings Americas (NHA) which is a subsidiary of Nomura Holdings Inc (NHI) registered 

with the JFSA.

Ahead of the SBSD registration, NGFP has been working with the SEC since 2017 to 

obtain model approval from the SEC for its credit risk Maximum Potential Exposure (MPE) 

model. NGFP has VAR model approval for Market Risk capital under SEC rule 240.15c3-1f. In 

addition, NHI has VAR, Stressed VAR and Incremental Risk Charge models approved under the 

JFSA’s capital adequacy requirements consistent with the capital requirements issued by the 

Basel Committee on Banking Supervision. 

NGFP intends to file their application for model approval with the NFA on or before 

October 6, 2021. NGFP will file the Chief Risk Officer certification that both model requirements 

NGFP is following are substantially compliant with the CFTC regulations. NGFP will provide 

prompt notification to the Division of the SEC’s approval or denial of its credit risk model 

application. NGFP will file its 4S attestation stating that they have policies and procedures 

reasonably designed to support our compliance with the CFTC capital regulations. Lastly, NGFP 

will maintain compliance with the minimum capital requirements under regulation 

23.101(a)(1)(ii) on October 6, 2021.
FOIA CONFIDENTIAL TREATMENT REQUESTED PURSUANT TO 5 U.S.C. § 552 AND 17 CFR § 145.

Request

Given that a complete application for NGFPs MPE model is pending at the SEC, NGFP 

request relief from regulations 23.102(f)(1) and 23.103 for NGFP to use its credit risk model that 

is currently pending approval with the SEC to compute its regulatory capital under CFTC 

regulation 23.101(a)(1)(ii) in lieu of the standardized charges required under regulation 23.103. 

NGFP requests this relief on a time-limited basis not to exceed November 1, 2021. 

In addition, NGFP requests to amend its election pursuant to CFTC Rule 23.102(f)(1) to 

calculate regulatory market risk capital charges 23.101(a)(1)(ii) using Market Risk models 

pending approval by the JFSA. 

Please let us know if you have any questions or require additional information.

Sincerely,

______________________________

Meghan Sullivan

Executive Director

Meghan.Sullivan@nomura.com

CC: Bruce Jin

Managing Director

Americas Chief Risk Officer

bruce.jin@nomura.com