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ARTICLE · 16 JUNE 2020

CFTC Extends COVID-19-Related No-Action Relief

Hogan Lovells Cadwalader
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The relief, formerly set to expire on June 30, 2020, is now extended until September 30, 2020.

United StatesFinance and Banking
Hogan Lovells Cadwalader
Hogan Lovells Cadwalader
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The CFTC's Division of Swap Dealer and Intermediary Oversight ("DSIO") and Division of Market Oversight ("DMO") extended relief previously provided to CFTC registrants due to compliance challenges caused by COVID-19. The relief, formerly set to expire on June 30, 2020, is now extended until September 30, 2020.

As previously covered, the DSIO on March 17, 2020 issued a series of no-action letters: Letter 20-03 to futures commission merchants ("FCMs") and introducing brokers ("IBs"); Letter 20-06 to swap dealers ("SDs"); and Letter 20-05 to retail foreign exchange dealers, granting relief from:

  1. recording oral communications, provided that certain requirements are met, including the creation and maintenance of a written record of the oral communication (including date, time, identifying information of the persons participating, and subject matter of the communication); and

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