ARTICLE
23 July 2020

CFTC DSIO Extends No-Action Relief On Registration Fingerprint Requirement

HL
Hogan Lovells Cadwalader

Contributor

Hogan Lovells Cadwalader is a global law firm trusted by clients to deliver on complex, high-stakes matters.

Operating at the intersection of business, finance, and government, we bring an unwavering commitment to client service and the decisive counsel that helps clients achieve exceptional results.

Consistently recognized for innovation across legal services, we combine sharp judgment with deep commercial perspective and intellectual rigor to address critical, cutting-edge challenges.

With 3,100 lawyers worldwide, we offer global scale with strong local insight in the markets that matter most. Our commitment extends beyond client work through pro bono activities, community investment, and responsible business practices.

As previously covered, the DSIO granted temporary relief to associated persons under CFTC Rule 3.10 ("Principal Registrations") and Rule 3.12 ("Associated Person Registrations").
United States Finance and Banking
Hogan Lovells Cadwalader are most popular:
  • within Intellectual Property, Government, Public Sector, Food, Drugs, Healthcare and Life Sciences topic(s)
  • with readers working within the Consumer Industries industries

The CFTC Division of Swap Dealer and Intermediary Oversight ("DSIO") extended relief from July 23, 2020 to September 30, 2020 to principals and associated persons from rules requiring a fingerprint card when registering with the Commission.

As previously covered, the DSIO granted temporary relief to associated persons under CFTC Rule 3.10 ("Principal Registrations") and Rule 3.12 ("Associated Person Registrations"). The relief is conditional upon the sponsoring firm completing a criminal background check that does not reveal any matters that would subject the applicant to statutory disqualification under Sections 8a(2) and 8a(3) of the Commodity Exchange Act. Upon NFA's announcement that it has resumed processing, applicants will have 30 days to submit their fingerprints.

Primary Sources

  1. CFTC No-Action Letter 20-20: Time Extension for No-Action Position in Response to the COVID-19 Pandemic for Persons Required to Submit Fingerprints in Connection with Applying for Registration as an Associated Person...
  2. CFTC Press Release: CFTC Extends Targeted Relief to Market Participants in Response to COVID-19

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

[View Source]

Mondaq uses cookies on this website. By using our website you agree to our use of cookies as set out in our Privacy Policy.

Learn More