On March 17, 2020, the Commodity Futures Trading Commission
("CFTC") issued a series of no-action letters
designed to provide regulated entities with relief from certain
obligations in response to the growth of COVID-19. Specifically,
the Division of Swap Dealer and Intermediary Oversight
("DSIO") issued five no-action letters providing relief
to futures commission merchants, introducing brokers, swap dealers,
retail foreign exchange dealers, floor brokers, and other market
participants (collectively, "DSIO Regulated Entities").
See CFTC Staff Letters 20-02, 20-03, 20-04, 20-05, 20-06. Simultaneously, the Division of Market
Oversight ("DMO") issued three no-action letters providing
similar relief to swap execution facilities and certain designated
contract markets. See CFTC Staff Letters 20-07, 20-08 and 20-09.