NFA continues to closely monitor the latest developments related to Coronavirus (COVID-19) and its significant impacts on NFA Members and the derivatives industry. NFA is committed to providing timely information and guidance for its Members. New information will be posted on this page as it becomes available.
Many of the orders list financial institutions as essential businesses and permit critical on site functions to continue, subject to limitations.
Several state orders, or guidance and FAQs issued in connection with state orders, refer to the Department of Homeland Security’s Cybersecurity and Infrastructure Agency (CISA) Memorandum issued on March 28, 2020. (Note: This document supersedes the CISA Memorandum issued on March 19, 2020.) The guidance identifies financial services workers as essential to continued infrastructure viability during the Coronavirus pandemic. On March 24, 2020, U.S. Treasury Secretary Steven T. Mnuchin issued a statement supporting CISA's guidance identifying financial services sector workers as essential.
Below are links to NFA's latest Coronavirus-related Notices to Members, along with brief summaries of each. Members should be sure to click and read each Notice in its entirety for full details, rather than relying on the Notice summaries on this page.
March 26, 2020 | I-20-16: Coronavirus (COVID-19) Update—Regulatory Relief for IBs
NFA issued automatic relief for all independent IB Members by providing a 30 calendar day extension for filing certified financial reports for fiscal years ending in December 2019 through March 2020. NFA is also providing all independent IB Members with a 10 business day extension for filing the semi-annual, quarterly or monthly reports for reporting periods ending February through April 2020.
March 23, 2020 | I-20-15: Coronavirus (COVID-19) Update—Regulatory Relief for CPOs and CTAs
NFA issued similar relief from NFA requirements as the CFTC's March 20, 2020 no-action relief letter to CPOs. The relief extends deadlines for upcoming CPO Form PQR filings, pool annual reports and periodic account statements for pool participants. NFA also extended deadlines for CTA Form PR filings due on or before April 30, 2020.
March 18, 2020 | I-20-13: Coronavirus Update—Regulatory Relief
NFA issued similar relief from NFA requirements as the CFTC 's March 17, 2020 no-action relief letters to FCMs, IBs, SDs and FDMs that are designed to facilitate the separation of personnel in response to the COVID-19 pandemic. NFA also provided FDMs a 30-day extension to the filing deadline for Chief Compliance Officer Annual Reports.
March 13, 2020 | I-20-12: Coronavirus Update—NFA Branch Office Requirements
Provided Members implement alternative supervisory methods to adequately supervise APs' activities and meet recordkeeping requirements, NFA will not pursue a disciplinary action against a Member that permits APs to temporarily work from locations not listed as a branch office and without a branch manager. Members should ensure these procedures are documented. NFA expects these APs will return to the Member's main office or listed branch office location once a Member firm is no longer operating under contingencies pursuant to its Business Continuity Plan (BCP).
March 12, 2020 | I-20-11: Information on CFTC Regulatory Reporting Requirements
Market volatility and the spread of the Coronavirus is an increasing reminder to SD Members of their regulatory reporting obligations, including notifying the CFTC if a SD implements a teleworking plan or activates its BCP where such implementation or activation is for purposes other than testing. NFA and CFTC regulatory coordination has increased during this pandemic.
March 4, 2020 | I-20-10: Information on Coronavirus/COVID-19
NFA encourages each Member to review its BCP and ensure its effectiveness should it need to be activated. Each Member should ensure its current listing of key employees and contact information is accurate, and its BCP should include appropriate measures that allowing it to operate efficiently during a pandemic.
Although NFA staff are working remotely, NFA continues to perform day-to-day regulatory oversight of its Members, including conducting exams, financial analysis, disclosure document reviews and investigatory work.
NFA understands that our Member firms' resources are focused on a number of priorities including employee safety, client service and critical operational issues. If an NFA Member needs an extension or accommodation to an NFA request, please contact the NFA employee making the request to discuss potential alternatives.
NFA's Registration staff is working remotely and effectively processing registration applications. Staff is also providing extensions to deadlines for submitting certain registration materials (e.g., Series 3 and related proficiency requirements, responses to fingerprint card deficiencies). Contact NFA's Information Center with any questions or concerns.
Due to concerns about the spread of the Coronavirus, NFA's Chicago office is suspending its applicant fingerprinting service until further notice. Fingerprinting services may be available at police stations, local law enforcement agencies or passport agencies.
Prometric, the administrator of NFA's proficiency examinations, has temporarily closed its test centers in the United States and Canada for a period of 30 days, starting March 18. For more information on the closing, click here.
Note that NFA's Swaps Proficiency Requirements are administered online and have not been impacted by the Coronavirus pandemic.
March 20, 2020 | I-20-14: Immediate attention required – Financial Requirements Section 12 – Increases in required minimum security deposits for forex transactions
Given market volatility and margin increases implemented by CME and ICE with respect to foreign currency futures, NFA has increased the minimum security deposits required to be collected and maintained by FDMs to 7% for the Norwegian Krone and 10% for the Mexican Peso.
NFA's Treasurer's Office continues to operate remotely. Members may access their daily invoices via the Online Registration System (ORS) Dashboard and should note that the invoices will not be mailed out. NFA encourages Members to check the ORS Dashboard regularly.
Additionally, to ensure timely processing, Members should send all payments to NFA's lockbox address (not to NFA's Chicago office).
Chicago, IL 60693-0001
The CFTC has created a dedicated webpage to highlight their actions related to COVID-19, as well as useful resources. The page contains a message from CFTC Chairman Heath Tarbert, no-action relief letters and a Customer Advisory message.
March 28, 2020 - CISA Memorandum on Identification of Essential Critical Infrastructure Workers during COVID-19 Response Version 2.0 (Note: This document supersedes the CISA Memorandum published on March 19, 2020, listed below.)
NFA is committed to providing the investing public with resources related to the evolving COVID-19 pandemic.
CFTC Customer Advisory: Be on Alert for Frauds Seeking to Profit from Market Volatility Related to COVID-19
Fraudsters commonly use major news events, such as the spread of COVID-19, to add credibility to their cons or manipulate emotions. In this Advisory, the CFTC provides customers with tips for protecting themselves from fraud, as well as information about reporting frauds they encounter.
If you believe that an NFA Member has treated you improperly or has improper business practices, NFA strongly encourages you to file a complaint. Including as much information as possible when filing a complaint will help NFA identify potential violations. You can use NFA's BASIC system to obtain NFA membership information for firms and individuals.