CFTC Staff Extends Temporary Relief from Fingerprinting Requirements for Associated Persons and Principals of Certain CFTC-Registered Entities

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July 17, 2020 TO: ICI Members
Chief Compliance Officer Committee
Derivatives Markets Advisory Committee
Investment Advisers Committee
Registered Fund CPO Advisory Committee SUBJECTS: Compliance
Derivatives
Investment Advisers RE: CFTC Staff Extends Temporary Relief from Fingerprinting Requirements for Associated Persons and Principals of Certain CFTC-Registered Entities

 

In April, in light of challenges caused by the COVID-19 pandemic, the Division of Swap Dealer and Intermediary Oversight (DSIO) of the Commodity Futures Trading Commission issued time-limited no-action relief in CFTC Staff Letter No. 20-16 (“Letter 20-16”)[1] to registrants including commodity pool operators and commodity trading advisors, from the requirement to submit a fingerprint card for new principals and applicants for registration as associated persons. The relief provided in Letter 20-16 would have expired on July 23, 2020.

Given that the COVID-19 related challenges that prompted the issuance of Letter 20-16 continue to be widespread, the National Futures Association (NFA) has requested, and DSIO has granted, a time-limited extension of the relief provided in Letter 20-16 until September 30, 2020, or until such earlier date as NFA notifies the public that it has resumed the processing of fingerprints, subject to the terms and conditions in Letter 20-16.[2]

 

Sarah A. Bessin
Associate General Counsel

 

endnotes

[1] For a summary of Letter 20-16 and a link to the letter, please see ICI Memorandum No. 32417 (Apr. 24, 2020), available at https://www.ici.org/my_ici/memorandum/memo32417.

[2] CFTC Letter No. 20-20 (July 14, 2020), available at https://www.cftc.gov/csl/20-20/download.