NFA Extends Recordkeeping Compliance Relief for Members

NFA extended relief previously provided to futures commission merchants ("FCMs") / introducing brokers ("IBs"), swap dealers ("SDs") and forex dealer members ("FDMs") from certain recordkeeping requirements. The prior expiration date of June 30, 2020 was extended until September 30, 2020. NFA's action follows recent extensions by the CFTC regarding similar relief.

As previously covered, NFA offered no-action relief, consistent with CFTC time-period extensions, concerning:

• NFA Compliance Rules 2-10 ("Recordkeeping") and 2-49 ("Swap Dealers and Major Swap Participants Regulations"), for FCMs/IBs and SDs, respectively, which mandate certain recordkeeping requirements, including timestamping and recording oral communications; and

• NFA Compliance Rule 2-36 ("Requirements for Forex Transactions"), which in part mandates that FDMs comply with certain CFTC timestamping requirements.

NFA noted there were no additional extensions for the previously issued relief with respect to the required submission of annual chief compliance officer reports by FCMs, IBs, SDs and FDMs. The filing deadlines for such reports remain the same.