Partial continuation of no-action positions to facilitate physical separation of registrant personnel in response to the COVID-19 pandemic

Exemptive relief to registered Introducing Broker for filing a certified financial report under Regulation 1.10 and Regulation 1.16.

Partial continuation of no-action positions to facilitate physical separation of registrant personnel in response to the COVID-19 pandemic

This no-action letter extends until January 15, 2021, the relief previously provided by CFTC Staff Letter 20-19, which, in turn, extended the time period for certain no-action relief provided in CFTC Staff Letters 20-02, 20-03, 20-04, 20-05, 20-06, 20-07, and 20-09, each issued on March 17, 2020 (the ""COVID-19 Letters"").

No-action positions for futures commission merchants and introducing brokers to address net capital treatment of covered loans under the CARES Act in response to the COVID-19 pandemic.

No-action positions for floor brokers to facilitate physical separation of personnel in response to the COVID-19 pandemic

No-action positions for futures commission merchants and introducing brokers to facilitate physical separation of personnel in response to the COVID-19 pandemic

No-action relief was granted to an entity from the statutory disqualification condition of CFTC Staff Letter No. 12-70 with repsect to its affiliate support activities.

The guidance clarifies the CIP and BO requirements applicable to introducing brokers (IBs) under the Bank Secrecy Act (BSA). The guidance provides regulatory clarity to certain IBs who lack access to the information needed to comply with CIP and BO obligations. The guidance eliminates duplicative efforts without impacting money laundering or terrorist financing risk, as the customer due diligence obligations will continue to be performed by the futures commission merchant (FCM) that carries the customer account.

No-action relief granted to an entity for its branch from registration as an IB pursuant to CEA Section 4d(g) to provide sufficient time for the Commission to review the entity’s 30.10 Petition, subject to certain conditions.