On March 17, 2020, the Division of Swap Dealer and Intermediary Oversight (“DSIO”) and the Division of Market Oversight (“DMO”) of the U.S. Commodity Futures Trading Commission (“CFTC”) issued a number of no-action letters providing temporary, targeted relief to futures commission merchants, introducing brokers, swap dealers, retail foreign exchange dealers, floor brokers, and swap execution facilities and designated contract markets, in response to the COVID-19 (coronavirus) pandemic. CFTC staff noted in a release announcing the relief that the spread of coronavirus has caused compliance with certain CFTC requirements to be particularly challenging or impossible because of displacement of registrant personnel from their normal business sites due to social distancing and other measures.
The CFTC’s release quoted CFTC Chairman Heath P. Tarbert in explaining the CFTC’s rationale for providing the relief granted in each letter: “These prudent, targeted, and temporary actions will help facilitate orderly trading and liquidity in our derivatives markets. The CFTC remains squarely focused on promoting their integrity, resilience, and vibrancy through sound regulation[.]”