{"id":"AGY-FED-FINANCIAL-067","kind":"order","level":"federal","jurisdiction":"United States; Commodity Futures Trading Commission, Division of Swap Dealer and Intermediary Oversight (federal staff no-action letter)","state":"","metro":"","industry":"","agency":"FED-FINANCIAL","eco":"","issuer":"CFTC Division of Swap Dealer and Intermediary Oversight (Director Joshua B. Sterling) and Division of Market Oversight","authority":"17 C.F.R. § 140.99; delegated authority","instrument":"CFTC Staff Letter No. 20-02 (No-Action)","title":"No-Action Positions for Certain Members of Designated Contract Markets and Swap Execution Facilities to Facilitate Physical Separation in Derivatives Industry Response to COVID-19","dateIssued":"2020-03-17","effective":"2020-03-17","end":"2020-06-30, extended to 2020-09-30 (Letter 20-19) and 2021-01-15 (Letter 20-26, Ex. 071); continued in part by Letters 21-04 and 21-10","startDate":"2020-03-17","endDate":"2021-03-31","quarters":["2020Q2","2020Q3","2020Q4","2021Q1"],"types":["TELE","EMP","OTHER"],"addressees":["members of designated contract markets and swap execution facilities not registered with the Commission"],"clause":"In connection with an industry-wide response to the COVID-19 pandemic, no-action [relief is provided to]... [members of DCMs and SEFs who]... [operate from alternative or remote locations, from the requirements to record oral communications and to time-stamp orders]. I. DSIO No-Action Position [the Division will not recommend enforcement action against such members for failure to comply with the cited recording requirements until June 30, 2020].","enforcement":"No-action position only; 7 U.S.C. § 6g and 17 C.F.R. § 1.35 otherwise enforceable","functions":["CM trading floors and dealing desks dispersed to remote locations","OP recording and surveillance systems","HR","WF"],"notes":"Guidance (no-action); records the Commission staff\u0027s finding that \u0027physical separation\u0027 of trading personnel was the industry response to the orders","sourceUrl":"https://www.cftc.gov/csl/20-02/download","snapshot":"","fileExists":true,"fileBytes":101621,"grade":"primary","character":"","description":"","collection":"AGY-FED-FINANCIAL","url":"/library/AGY-FED-FINANCIAL-067","exhibitUrl":"/exhibit/AGY-FED-FINANCIAL-067","citation":"CFTC Division of Swap Dealer and Intermediary Oversight (Director Joshua B. Sterling) and Division of Market Oversight, CFTC Staff Letter No. 20-02 (No-Action) (Mar. 17, 2020) (Ex. AGY-FED-FINANCIAL-067)","stateName":"","related":[]}