The COVID Project
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
2020 Q22020 Q32020 Q42021 Q12021 Q22021 Q3
- 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 noteTreated as guidance per the assignment.