What is a swap dealer?

A swap dealer is a company that makes a business of dealing in swaps, the privately negotiated derivative contracts used to trade or hedge things like interest rates, currencies and commodities. In the US, swap dealers are regulated by the Commodity Futures Trading Commission (CFTC), whose wider crypto role is covered in what does the CFTC do in crypto. Registration brings capital, margin and conduct rules similar to those that apply to big bank dealers.

What does a swap dealer do?

It stands ready to trade swaps with clients for its own account. The NFA, citing CFTC Regulation 1.3, says a swap dealer is an entity that holds itself out as a dealer in swaps, makes a market in swaps, regularly enters swaps for its own account in the ordinary course of business, or is commonly known in the trade as a dealer or market maker. In practice, that usually means banks and large trading firms that give clients a price and manage the resulting risk, much like a crypto market maker does in spot markets.

The term swap is broad. The CFTC has clarified that certain transactions count as swaps, including commodity options, which is why an options business can need swap dealer registration.

How does CFTC swap dealer registration work?

The CFTC has handed registration work to the NFA. An applicant files Form 7-R, applies for NFA membership, pays a $15,000 application fee plus dues, and files Form 8-R and fingerprints for each principal, according to the NFA. It must also show it complies with the CFTC's swap dealer rules. Every registered swap dealer must be an NFA member, and staff who act for it must meet NFA's swaps proficiency requirements.

Once registered, a dealer must meet requirements on capital and margin, reporting and recordkeeping, business conduct, documentation, and segregation of customer funds for uncleared swaps, and must name a chief compliance officer, the CFTC says. The NFA also examines swap dealers and publishes a public registry of them.

What is the swap dealer de minimis threshold?

It is the amount of dealing a firm can do before it must register. A CFTC final rule of November 13, 2018 set the threshold permanently at $8 billion in aggregate gross notional amount of swap dealing over the previous 12 months, instead of letting it drop to $3 billion. Firms below that level can rely on the exception.

Can a crypto firm be a swap dealer?

Yes. On November 5, 2026, The Block reported that Anchorage Digital Swap Dealer, LLC had filed with the NFA to register. If approved, it plans to offer European-style options on bitcoin and ether with terms of up to a year to institutional clients. The Defiant reported that Anchorage said its options business had crossed the $8 billion exemption level. As of November 5, 2026, the application was pending, and Anchorage's CEO gave no timeline.

Rules differ by country and change often. Check the CFTC, the NFA or a qualified professional for a specific case.