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
- 2020-04-24 Apr. 24, 2020
- Effective
- 2020-04-24
- End
- Extended by Letter 20-20 (July 14, 2020) to 2020-09-30 (read as 2020-07-14)
- In force
- Apr. 24, 2020 to July 14, 2020
- Quarters
- 2020 Q22020 Q3
2020 Q22020 Q32020 Q42021 Q12021 Q22021 Q3
- Limitation types
- Workplace rulesOther
- Addressees
- applicants for registration as associated persons
- sponsoring FCMs, IBs, CPOs and CTAs
- the National Futures Association
- Functions reached
- HR hiring and registration of associated persons (fingerprinting unavailable)
- OP compliance
- Collection
- Federal financial regulators AGY-FED-FINANCIAL
Operative words
[The National Futures Association has advised that] it has suspended its applicant fingerprinting service, and that this fact (combined with the [closure of other fingerprinting locations under State orders]) [prevents applicants from submitting the] fingerprints of the natural person on a fingerprint card [that must] accompany his or her Form 8-R.
Enforcement
No-action position only; 17 C.F.R. § 3.12 otherwise enforceable
Notes
Documents that fingerprinting services were closed; the hiring pipeline of every futures intermediary depended on them