NFA extended relief from certain recordkeeping requirements to futures commission merchants ("FCMs") / introducing brokers ("IBs"), swap dealers ("SDs") and forex dealer members ("FDMs") through January 15, 2021. The relief, which was issued in response to the pandemic, was previously set to expire on September 30, 2020. NFA's extension follows similar no-action relief by the CFTC (see previous coverage).

The extended relief, as outlined previously in Notice I-20-13, concerns:

  • NFA Compliance Rule 2-10 (for FCMs and IBs) and Compliance Rule 2-49 (for SDs), which mandate certain recordkeeping requirements, including timestamping and recording oral communications; and
  • NFA Compliance Rule 2-36, which requires an FDM to prepare and file a chief compliance officer annual report.

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.