The National Futures Association ("NFA") reminded swap dealer registrants of their regulatory reporting requirements in the midst of the coronavirus pandemic.
Under CFTC Rule 23.603 ("Business continuity and disaster recovery"), swap dealers must establish and maintain written business continuity and disaster recovery plans outlining procedures to be followed during emergencies or other disruptions of normal business activities ("Business Continuity Plans"). The NFA stated that swap dealers must notify the CFTC when activating their Business Continuity Plan or teleworking plan for purposes other than testing.
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