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CFTC Relief Updates

March 18th | 2020

The CFTC, through its Division of Swap Dealer and Intermediary Oversight (DSIO), has issued a number of no-action letters providing temporary, targeted relief to futures commission merchants, introducing brokers, swap dealers, retail foreign exchange dealers, floor brokers, and other market participants in response to the COVID-19 pandemic.


Subject to the conditions stated in the letters, the relief provided is as follows:


  • Relief for Futures Commission Merchants and Introducing Brokers. DSIO has granted temporary, targeted no-action relief to futures commission merchants and introducing brokers from CFTC regulations requiring recording of oral communications related to voice trading and other telephonic communications as well as time-stamping requirements when located in remote, socially-distanced locations. DSIO has also granted 30 days of no-action relief to futures commission merchants from the requirement to furnish annual compliance reports to the CFTC. [See CFTC Letter No. 20-03]

  • Relief for Swap Dealers. DSIO has granted temporary, targeted no-action relief to swap dealers from CFTC regulations requiring recording of oral communications related to voice trading and other telephonic communications as well as time-stamping requirements when located in remote, socially-distanced locations. DSIO has also granted 30 days of no-action relief to swap dealers from the requirement to furnish annual compliance reports to the CFTC. [See CFTC Letter No. 20-06]

  • Relief for Retail Foreign Exchange Dealers. DSIO has granted temporary, targeted no-action relief to retail foreign exchange dealers from CFTC regulations requiring recording of oral communications related to voice trading and other telephonic communications as well as time-stamping requirements when located in remote, socially-distanced locations. [See CFTC Letter No. 20-05]

  • Relief for Floor Brokers. DSIO has granted temporary, targeted no-action relief to floor brokers from CFTC regulations requiring recording of oral communications related to voice trading and other telephonic communications as well as time-stamping requirements when located in remote, socially-distanced locations. DSIO has also granted relief from the requirement to be located on the premises of a designated contract market and to register as introducing brokers, which might otherwise have been triggered in connection with trading activities undertaken at remote, socially-distanced locations. [See CFTC Letter No. 20-04]

  • Relief for Members of Designated Contract Markets and Swap Execution Facilities. DSIO has granted temporary, targeted no-action relief to members of designated contract markets and swap execution facilities from time-stamping requirements when located in remote, socially-distanced locations [See CFTC Letter No. 20-02].

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