CFTC Provides Relief to Market Participants in Response to COVID-19: DSIO and DMO Issue No-Action Letters Granting Temporary, Conditional Relief to CFTC Registrants for Recordkeeping Requirements for Oral Communications, Time-Stamping Requirements and for the Filing of Annual Compliance Reports

Sullivan & Cromwell LLP - March 17, 2020

On March 17, 2020, the Division of Swap Dealer and Intermediary Oversight and the Division of Market Oversight of the U.S. Commodity Futures Trading Commission 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.