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Ex. AGY-FED-FINANCIAL-068 Order Primary source read

CFTC Staff Letter No. 20-03 (No-Action)

Temporary Relief for Futures Commission Merchants and Introducing Brokers to Facilitate Physical Separation in Derivatives Industry Response to COVID-19

CFTC Division of Swap Dealer and Intermediary 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
Issued
2020-03-17 Mar. 17, 2020
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) (read as 2021-06-30)
In force
Mar. 17, 2020 to June 30, 2021
Quarters
2020 Q22020 Q32020 Q42021 Q12021 Q2
Limitation types
Telework mandateWorkplace rulesOther
Addressees
  • futures commission merchants
  • introducing brokers
  • their associated persons
Functions reached
  • CM brokerage operations from remote locations
  • OP recording, time-stamping and branch-office registration
  • HR
  • WF
Collection
Federal financial regulators AGY-FED-FINANCIAL

Operative words

[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

Notes

The staff's contemporaneous finding that FCM and IB personnel were working from remote locations; guidance