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
- 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
2020 Q22020 Q32020 Q42021 Q12021 Q22021 Q3
- 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
Notes
The staff's contemporaneous finding that FCM and IB personnel were working from remote locations; guidance