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CFTC Extends COVID-19-Related No-Action Relief

June 22nd | 2020



The CFTC extended relief previously provided to CFTC registrants due to compliance challenges caused by COVID-19. Certain aspects of relief have been extended until September 30, 2020, subject to the terms and conditions in CFTC Staff Letters Nos. 20-02, 20-03, 20-04, 20-05, 20-06, 20-07, and 20-09, each issued on March 17, 2020. Below the CFTC’s extended relief is broken out by type of registrant.


Futures Commission Merchants (“FCM”) & Introducing Brokers (“IB”)

  • Recording of oral communications in accordance with Commission regulation 1.35.

  • Time-stamps in accordance with Commission regulations 1.35 or 155.3.

Swap Dealers (“SD”)

  • Recording of oral communications in accordance with Commission regulation 23.202.

  • Time-stamps in accordance with Commission regulation 23.202.

Retail Foreign Exchange Dealers (“RFED”)

  • Recording of oral communications in accordance with Commission regulation 1.35.

  • Time-stamps in accordance with Commission regulations 1.35 or 5.18.

Floor Brokers (“FB”)

  • Recording of oral communications in accordance with Commission regulation 1.35.

  • Time-stamps in accordance with Commission regulations 1.35.

  • Location requirement pursuant to the definition of “floor broker” in Commission regulation 1.3.

  • Introducing broker registration.

Designated Contract Markets (“DCM”)

  • Audit trail and related requirements pursuant to CEA sections 5(d)(4) and (10) and Commission regulations thereunder.

Swap Execution Facilities(“SEF”)

  • Recording of voice communications pursuant to Commission regulations 37.205(a)-(b), 37.400(b), 37.406, 37.1000(a)(1), and 37.1001.

Unregistered Swap Execution Facilities (“Members”)

  • Time-stamps in accordance with Commission regulation 1.35.

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