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 (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
- Functions reached
- CM swap dealing desks (banks' derivatives businesses)
- OP recordkeeping
- WF
- Collection
- Federal financial regulators AGY-FED-FINANCIAL
Operative words
Re: No-Action Positions for Swap Dealers to Facilitate Physical [Separation in Derivatives Industry Response to COVID-19]. This letter is in response to a request received by the Division of Swap Dealer and [Intermediary Oversight]... [regarding the recordkeeping] obligations of persons that are registered with the Commission as swap dealers ('SDs') [whose personnel are working from remote locations].
Enforcement
Notes
Reached the swap-dealer arms of the largest banks; guidance