Notices to Members

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Notice I-20-10

March 4, 2020

Information on Coronavirus/COVID-19

NFA takes the world-wide spread of the Coronavirus extremely seriously and is closely monitoring this fluid situation.

NFA is aware that Members are developing contingency plans to deal with the potential impact of the Coronavirus on their operations. In light of these preparations, we also understand that Members may have specific concerns regarding their ability to comply fully with CFTC and NFA regulatory requirements, particularly in the event that some or all of their staff are not able to work in Member firms' offices or backup facilities. We have been coordinating with the various industry trade associations with respect to the potential areas of concern. NFA and CFTC staff have been in regular contact regarding these and other developing issues, including the possible need for regulatory relief. In the event that regulatory relief is necessary, NFA and CFTC staff intend to take a practical approach that will give Members appropriate flexibility in implementing contingency plans needed to continue to conduct business.

NFA also encourages all Members to review their business continuity plans (BCPs) to ensure that they are up to date (e.g., current listing of key employees and their contact information) and include appropriate measures to address the Coronavirus situation and allow Members to operate effectively during this time. Members should also consider providing employees with additional or refresher training on topics related to operating from a remote location.

Many NFA Members address pandemics in their BCPs or have recently updated their plans to do so. Although the Coronavirus has not been declared a pandemic, we strongly encourage Members to ensure that their plans address this type of situation. Members should identify key relationships (e.g., clearing firms, telecommunications networks, third party providers, internal departments, mail or email services, utilities, etc.), assess the risks a pandemic poses to those relationships, and understand how a pandemic may materially impact their businesses.

NFA recognizes the evolving nature of the Coronavirus situation, and we encourage Members to keep us informed of any particular concerns or needs for regulatory relief.

Should you have any questions, please contact Valerie O'Malley, Director, Futures Compliance (312-781-1290 or vomalley@nfa.futures.org) or Joe Zangri, Managing Director, OTC Derivatives (212-346-5632 or jzangri@nfa.futures.org).

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