{"id":"AGY-FED-FINANCIAL-068","kind":"order","level":"federal","jurisdiction":"United States; Commodity Futures Trading Commission, Division of Swap Dealer and Intermediary Oversight (federal staff no-action letter)","state":"","metro":"","industry":"","agency":"FED-FINANCIAL","eco":"","issuer":"CFTC Division of Swap Dealer and Intermediary Oversight","authority":"17 C.F.R. § 140.99","instrument":"CFTC Staff Letter No. 20-03 (No-Action)","title":"Temporary Relief for Futures Commission Merchants and Introducing Brokers to Facilitate Physical Separation in Derivatives Industry Response to COVID-19","dateIssued":"2020-03-17","effective":"2020-03-17","end":"2020-06-30, extended to 2020-09-30 and 2021-01-15; limited continuation to 2021-03-31 / 2021-04-15 (Letters 21-04, 21-05)","startDate":"2020-03-17","endDate":"2021-06-30","quarters":["2020Q2","2020Q3","2020Q4","2021Q1","2021Q2"],"types":["TELE","EMP","OTHER"],"addressees":["futures commission merchants","introducing brokers","their associated persons"],"clause":"[FCMs and IBs have advised the Division that personnel will work from an] alternative or remote location during the COVID-19 pandemic. DSIO further expects [that such locations may lack the recording and time-stamping systems the regulations require]. DSIO will not recommend that the Commission take an enforcement action against any [FCM or IB for failure to comply with:] (1) Recording of Oral Communications. Until June 30, 2020, any requirement to make and keep records of oral communications pursuant to [Regulation 1.35(a)]. (2) Time-Stamps. Until June 30, 2020, any requirement to record the date and [time of order receipt and execution to the nearest minute].","enforcement":"No-action position only","functions":["CM brokerage operations from remote locations","OP recording, time-stamping and branch-office registration","HR","WF"],"notes":"The staff\u0027s contemporaneous finding that FCM and IB personnel were working from remote locations; guidance","sourceUrl":"https://www.cftc.gov/csl/20-03/download","snapshot":"","fileExists":true,"fileBytes":169513,"grade":"primary","character":"","description":"","collection":"AGY-FED-FINANCIAL","url":"/library/AGY-FED-FINANCIAL-068","exhibitUrl":"/exhibit/AGY-FED-FINANCIAL-068","citation":"CFTC Division of Swap Dealer and Intermediary Oversight, CFTC Staff Letter No. 20-03 (No-Action) (Mar. 17, 2020) (Ex. AGY-FED-FINANCIAL-068)","stateName":"","related":["AGY-FED-FINANCIAL-069","AGY-FED-FINANCIAL-070"]}