CFTC/NFA Expiration of Temporary No-Action Relief

October 1st | 2020

Earlier this year, the CFTC's Staff Letter No. 20-20 provided for temporary relief from fingerprinting requirements that would expire September 30, 2020 or earlier in the event the NFA notified the public that it has resumed processing fingerprints. Firms should be aware that the relief is not going to be extended beyond September 30.

The NFA is not taking walk-ins for fingerprinting, but is forwarding fingerprinting cards completed elsewhere – such as, for example, law enforcement offices – to the FBI for required background check procedure.

Thus, anyone who relied on the temporary relief should plan on submitting the required fingerprints to NFA by October 30, 2020. If a firm or person finds this deadline cannot be made due to extenuating circumstances, they should reach out to the NFA and the CFTC Division of Swap Dealer and Intermediary Oversight.

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