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Ex. AGY-FED-FINANCIAL-067 Order Primary source read

CFTC Staff Letter No. 20-02 (No-Action)

No-Action Positions for Certain Members of Designated Contract Markets and Swap Execution Facilities to Facilitate Physical Separation in Derivatives Industry Response to COVID-19

CFTC Division of Swap Dealer and Intermediary Oversight (Director Joshua B. Sterling) and Division of Market Oversight · United States; Commodity Futures Trading Commission, Division of Swap Dealer and Intermediary Oversight (federal staff no-action letter) (Federal)

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The record

Jurisdiction
United States; Commodity Futures Trading Commission, Division of Swap Dealer and Intermediary Oversight (federal staff no-action letter)
Level
Federal
Authority
17 C.F.R. § 140.99; delegated authority
Issued
2020-03-17 Mar. 17, 2020
Effective
2020-03-17
End
2020-06-30, extended to 2020-09-30 (Letter 20-19) and 2021-01-15 (Letter 20-26, Ex. 071); continued in part by Letters 21-04 and 21-10 (read as 2021-03-31)
In force
Mar. 17, 2020 to Mar. 31, 2021
Quarters
2020 Q22020 Q32020 Q42021 Q1
Limitation types
Telework mandateWorkplace rulesOther
Addressees
  • members of designated contract markets and swap execution facilities not registered with the Commission
Functions reached
  • CM trading floors and dealing desks dispersed to remote locations
  • OP recording and surveillance systems
  • HR
  • WF
Collection
Federal financial regulators AGY-FED-FINANCIAL

Operative words

In connection with an industry-wide response to the COVID-19 pandemic, no-action [relief is provided to]... [members of DCMs and SEFs who]... [operate from alternative or remote locations, from the requirements to record oral communications and to time-stamp orders]. I. DSIO No-Action Position [the Division will not recommend enforcement action against such members for failure to comply with the cited recording requirements until June 30, 2020].

Enforcement

No-action position only; 7 U.S.C. § 6g and 17 C.F.R. § 1.35 otherwise enforceable

Notes

Guidance (no-action); records the Commission staff's finding that 'physical separation' of trading personnel was the industry response to the orders

Retrieval note

Treated as guidance per the assignment.