{"id":"AGY-FED-FINANCIAL-069","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","authority":"17 C.F.R. § 140.99","instrument":"CFTC Staff Letter No. 20-06 (No-Action)","title":"No-Action Positions for Swap Dealers 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 and 2021-01-15","startDate":"2020-03-17","endDate":"2021-03-31","quarters":["2020Q2","2020Q3","2020Q4","2021Q1"],"types":["TELE","EMP","OTHER"],"addressees":["registered swap dealers"],"clause":"Re: No-Action Positions for Swap Dealers to Facilitate Physical [Separation in Derivatives Industry Response to COVID-19]. This letter is in response to a request received by the Division of Swap Dealer and [Intermediary Oversight]... [regarding the recordkeeping] obligations of persons that are registered with the Commission as swap dealers (\u0027SDs\u0027) [whose personnel are working from remote locations].","enforcement":"No-action position only","functions":["CM swap dealing desks (banks\u0027 derivatives businesses)","OP recordkeeping","WF"],"notes":"Reached the swap-dealer arms of the largest banks; guidance","sourceUrl":"https://www.cftc.gov/csl/20-06/download","snapshot":"","fileExists":true,"fileBytes":449830,"grade":"primary","character":"","description":"","collection":"AGY-FED-FINANCIAL","url":"/library/AGY-FED-FINANCIAL-069","exhibitUrl":"/exhibit/AGY-FED-FINANCIAL-069","citation":"CFTC Division of Swap Dealer and Intermediary Oversight, CFTC Staff Letter No. 20-06 (No-Action) (Mar. 17, 2020) (Ex. AGY-FED-FINANCIAL-069)","stateName":"","related":["AGY-FED-FINANCIAL-068","AGY-FED-FINANCIAL-070"]}