Notices to Members

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Notice I-20-37

October 6, 2020

Coronavirus Update—Expiration of Temporary Relief from Fingerprinting Requirements

In April 2020, the CFTC's Division of Swap Dealer and Intermediary Oversight (DSIO) issued a no-action letter granting temporary relief to registrants and applicants for registration listing a principal, and for applicants for associate person (AP) registration, from the fingerprinting requirements in CFTC Regulations 3.10(a)(2) (for natural person principals) and 3.12(c)(3) (for APs). NFA issued similar relief from the fingerprinting requirements in NFA Registration Rules 204(a)(2)(A) and 206(a)(1)(A). In July 2020, DSIO and NFA extended this relief until September 30, 2020.

On September 29, 2020, DSIO issued an email alert stating that this no-action relief would not be extended beyond September 30, 2020. Therefore, beginning on October 1, 2020, all applicants for AP registration and all natural persons being listed as a principal of an applicant or registrant must submit the applicant's or natural person principal's fingerprints on an applicant fingerprint card, which are available at facilities offering fingerprinting services.

Additionally, all persons currently relying on DSIO's no-action letter and NFA relief from the fingerprinting requirements and APs that have been granted a temporary license must submit a fingerprint card to NFA by November 2, 2020.

Any person finding it impossible or inordinately difficult to obtain fingerprints should contact NFA's Information Center (1-800-621-3570 or 312-781-1410 or

Timely information and guidance for Members and the investing public related to COVID-19 continues to be posted to NFA's dedicated COVID-19 webpage as it becomes available.

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