Home \ TRACER: Tracker of Regulatory Agencies Coronavirus Emergency Responses

TRACER: Tracker of Regulatory Agencies Coronavirus Emergency Responses

In response to the economic and financial impacts of the coronavirus epidemic, financial regulators have loosened rules, lowered capital requirements and suspended many important regulatory safeguards. These actions will help struggling families and small businesses make it through this difficult time. However, the administration must not be allowed to use this crisis as an excuse to permanently deregulate the financial system. That's why Better Markets launched TRACER.

About this Tracker

TRACER tracks every coronavirus-related action taken by financial regulators and is broken into three categories: BankingSecurities and DerivativesThe tracker gives a brief explanation of each measure with rollback dates, among other details, and provides timely updates of any relevant action taken by regulators. Through TRACER, Better Markets will report on this rollback process and hold the agencies accountable by flagging any and every measure that is not completely undone.

 

If you have questions about our process or information that is not included in our tracker, please reach out to us at tracker@bettermarkes.com

 

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 15, 2020

Summary of Action: Effective March 26, 2020, reserve requirements, or the amount banks have to hold as a percentage of deposits, are reduced to zero. Increases the potential liquidity for banks, allowing greater ability to lend.

https://www.federalreserve.gov/monetarypolicy/reservereq.htm

Nature of Action: Monetary policy authority under Section 9 of Federal Reserve Act.

Expires: No expiration given.
From FAQ: “Currently the Board has no plans to re-impose reserve requirements”

OCC, FRB, and FDIC
#6ec066

Date of Action: March 17, 2020

Summary of Action: Relaxes the definition of “eligible retained income,” which serves as a cap on the amount of capital distributions that banks with insufficient regulatory capital buffers can make. This will make the onset of capital distribution restrictions more gradual which, according to the agencies, will prevent banks from limiting lending, by incentivizing use of capital buffers for lending, in response to economic shocks (such as that caused by COVID-19). 

https://www.govinfo.gov/content/pkg/FR-2020-03-20/pdf/2020-06051.pdf

Nature of Action: Interim final rule.

Expires: No expiration given.
Deadline for comments on the interim final rule is May 4, 2020.

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 17, 2020

Summary of Action: Re-establishment of financial crisis bailout programs, including the Commercial Paper Funding Facility, to provide a backstop for commercial paper, and the Primary Dealer Credit Facility, to provide a liquidity backstop to primary dealers of FRBNY.

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200317a.htm

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200317b.htm

Nature of Action: Section 13 (3) authority. 

Expires: CPFF terminates on March 17, 2021; PDCF will operate for at least six months.

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 18, 2020

Summary of Action: Establishment of Money Market Mutual Fund Liquidity Facility to provide loans to financial institutions secured by assets purchased from money market mutual funds.

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200318a.htm

Nature of Action: Section 13(3) authority. 

Expires: Sept. 30, 2020

FRB, OCC, CFPB, FDIC, NCUA, CSSS
#6ec066

Date of Action: March 22, 2020

Summary of Action: Explanation of supervisory expectations during COVID-19 crisis, including that banks will work with customers impacted by the crisis, and explaining that actions such as loan modifications to support customers are viewed as positive action and will not lead to negative supervisory actions.

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200322a.htm; https://www.federalreserve.gov/supervisionreg/srletters/SR2004.htm

Nature of Action: Interagency statement; supervisory letter.

Expires: No expiration given.

Office of the Comptroller of the Currency (OCC)
#6ec066

Date of Action: March 22, 2020

Summary of Action: Allows Short-Term Investment Funds operated by national banks to have longer dollar-weighted average portfolio maturity (must be 60 days or less under the rule; can be 120 days or less under the relief) and dollar-weighted average portfolio life maturity (must be less than 120 days under the rule; can be 180 days or less under the relief).

https://www.occ.gov/news-issuances/news-releases/2020/nr-occ-2020-38.html

Nature of Action: Exemptive Order.

Expires: July 20, 2020

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 23, 2020

Summary of Action: Relaxes the definition of “eligible retained income,” which serves as a cap on the amount of capital distributions a bank can make. This will make the onset of capital distribution restrictions more gradual which, according to FRB, will prevent banks from limiting lending by incentivizing use of TLAC buffers for lending, in response to economic shocks (such as that caused by COVID-19).

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200323a.htm

Nature of Action: Interim final rule.

Expires: No expiration given. Deadlines for comments on the interim final rule is 45 days after publication in Federal Register. 

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 23, 2020

Summary of Action: Establishment of Primary Market Corporate Credit Facility and Secondary Market Corporate Credit Facility to provide liquidity for new and outstanding corporate bonds.

https://www.federalreserve.gov/monetarypolicy/pmccf.htm

https://www.federalreserve.gov/monetarypolicy/smccf.htm  

Nature of Action: Section 13 (3) authority. 

Expires: Sept. 30, 2020

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 23, 2020

Summary of Action: Re-establishment of Term Asset-Backed Securities Loan Facility, a crisis-era bailout program, to serve as a funding backstop to facilitate issuance of asset-backed securities.

https://www.federalreserve.gov/monetarypolicy/talf.htm

Nature of Action: Section 13(3) authority.

Expires: Sept. 30, 2020. 

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 24, 2020

Summary of Action: Delay in implementation of changes to Payment Systems Risk Policy, governing the provision of intraday credit to U.S. branches of foreign banks, from April 1 to Oct. 1, to allow banks to focus on heightened priorities (COVID-19) instead of establishing new arrangements for intraday credit.

https://www.federalreserve.gov/newsevents/pressreleases/other20200324a.htm

Nature of Action: Notice of delay. 

Expires: Delays implementation of PSRP changes to Oct. 1, 2020.

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 24, 2020

Summary of Action: FRB explanation of supervisory approach during crisis, including the following: (1) FRB will not criticize FIs that work with borrowers (consistent with interagency statement issued on March 22, 2020), (2) FRB will increase focus on monitoring and decrease focus on examinations (including ceasing exams for banks under $100 billion in assets), and (3) FRB will provide additional time to remediate supervisory findings. Banks still expected to submit CCAR plans by April 6, 2020.

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200324a.htm

Nature of Action: Agency statement.   

Expires: No expiration given. 

FEDERAL FINANCIAL INSTITUTIONS EXAMINATION COUNCIL (FFIEC)
#6ec066

Date of Action: March 25, 2020

Summary of Action: FFIEC agencies will not take action against banks that fail to submit March 31, 2020, call reports by the filing deadline as long as reports are filed by 30 days after the deadline.

https://www.ffiec.gov/press/pr032520.htm

Nature of Action: Agency statement. 

Expires: Banks have 30 additional days to submit call report. 

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 26, 2020

Summary of Action: FRB will not take action against small financial institutions, i.e. banks with less than $5 billion in assets, for submitting March 31, 2020, financial statements (FR Y-9C or FR Y-11, as applicable) after the deadline, so long as reports are filed by 30 days after the deadline.

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200326b.htm

Nature of Action: Agency statement

Expires: Banks have 30 additional days to submit required report. 

CONSUMER FINANCE PROTECTION BUREAU (CFPB)
#6ec066

Date of Action: March 26, 2020

Summary of Action: The CFPB will not cite in an examination, or initiate an enforcement action, for failure of an institution to report quarterly HMDA data (first quarterly submissions would be due on May 30).  Entities should continue collecting and recording HMDA data in anticipation of making annual data submissions.

https://files.consumerfinance.gov/f/documents/cfpb_hmda-statement_covid-19_2020-03.pdf

Nature of Action: Agency statement.

Expires: Until further notice.

CONSUMER FINANCE PROTECTION BUREAU (CFPB)
#6ec066

Date of Action: March 26, 2020

Summary of Action: The CFPB will not cite in an examination, or initiate an enforcement action, for failure of institutions to submit: (1) TILA annual reports on agreements between credit card companies and colleges; (2) quarterly submission of credit card agreements; (3) credit card pricing and availability information; and (4) prepaid account agreements.

https://files.consumerfinance.gov/f/documents/cfpb_data-collection-statement_covid-19_2020-03.pdf

Nature of Action: Agency statement. 

Expires: Until further notice. 

OCC, FRB, FDIC
#6ec066

Date of Action: March 27, 2020

Summary of Action: Allows banking organizations that adopt CECL during 2020 the option to delay, for two years, the estimated impact of CECL on regulatory capital, followed by a three-year transition to phase out aggregate capital benefit provided by the two-year phase in. 

https://www.federalregister.gov/documents/2020/03/31/2020-06770/regulatory-capital-rule-revised-transition-of-the-current-expected-credit-losses-methodology-for  

Nature of Action: Interim final rule. 

Expires: Banks have until the end of 2020 to adopt CECL to take advantage of the extended phase-in. Comments on the interim final rule are due May 15, 2020.

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: March 31, 2020

Summary of Action: Establishment of FIMA repurchase authority to allow central banks and other international monetary authorities to exchange U.S. Treasury Securities held with FRB for U.S. dollars.

https://www.federalreserve.gov/newsevents/pressreleases/monetary20200331a.htm

Nature of Action: FOMC action. 

Expires: Until at least Oct. 6, 2020. Six months after program begins on April 6, 2020. 

CONSUMER FINANCE PROTECTION BUREAU (CFPB)
#6ec066

Date of Action: April 1, 2020

Summary of Action: The CFPB will not cite in an examination, or bring an enforcement action, against firms that exceed the deadlines to investigate credit reporting disputes as long as they make “good faith efforts” during the pandemic to do so as quickly as possible.

https://files.consumerfinance.gov/f/documents/cfpb_credit-reporting-policy-statement_cares-act_2020-04.pdf

Nature of Action: Agency statement. 

Expires: No expiration given. 
 

FRB, FDIC, OCC
#6ec066

Date of Action: April 6, 2020

Summary of Action: Temporary reduction of the threshold for qualifying community banking organizations, i.e. those with less than $10 billion in assets and that meet certain other criteria, to meet capital and leverage requirements using the “community bank leverage” ratio, from 9 percent to 8 percent, for 2020 and to allow a two-quarter grace period for banks that fall below the 8 percent ratio so long as they stay above 7 percent community bank leverage ratio, a reduction from 8 percent, the previous threshold to be entitled to the grace period.

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200406a.htm

Nature of Action: Interim final rule.

Expires: The community banking leverage ratio goes to 8.5 percent for 2021 and to the previous level of 9 percent in 2022. Comments on the final rule are due 45 days from publication in the Federal Register.

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: April 6, 2020

Summary of Action: Establishment of facility to provide term financing backed by Paycheck Protection Program loans.

https://www.federalreserve.gov/newsevents/pressreleases/files/monetary20200409a6.pdf

Nature of Action: Section 13(3) authority. 

Expires: Sept. 30, 2020

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: April 8, 2020

Summary of Action: Temporary relief for Wells Fargo from growth restrictions imposed “because of widespread compliance and operational breakdowns that resulted in harm to consumers” and insufficient oversight by Wells Fargo’s board; loans made pursuant to Paycheck Protection Program and FRB’s Main Street Business Lending Program do not count toward cap.

https://www.federalreserve.gov/newsevents/pressreleases/enforcement20200408a.htm

Nature of Action: Amendment to consent order.

Expires: Loans excluded from cap must be made pursuant to PPP (expires June 30, 2020) or Main Street Business Lending Program (expires Sept. 30, 2020).

FEDERAL RESERVE BANK (FRB)
#6ec066

Date of Action: April 9, 2020

Summary of Action: Establishment of Main Street Business Lending Program to provide funds for purchasing loan participations, to facilitate lending to small- and medium-sized businesses by banks.

https://www.federalreserve.gov/newsevents/pressreleases/files/monetary20200409a7.pdf

https://www.federalreserve.gov/newsevents/pressreleases/files/monetary20200409a4.pdf

Nature of Action: Section 13(3) authority.  

Expires: Sept. 30, 2020

FRB, FDIC, OCC
#6ec066

Date of Action: April 9, 2020

Summary of Action: Establishment of zero percent risk weight for PPP loans, to neutralize the regulatory capital effects of participating in FRB’s PPP facility. 

https://www.federalreserve.gov/newsevents/pressreleases/bcreg20200409a.htm

Nature of Action: Interim final rule.

Expires: No expiration given. Comments on interim final rule due 30 days from publication in Federal Register.

CONSUMER FINANCE PROTECTION BUREAU (CFPB)
#6ec066

Date of Action: April 10, 2020

Summary of Action: Until Jan. 1, 2021, the Bureau will not cite a supervisory violation or recommend enforcement action where remittance transfer providers give customers estimates of exchange rates and third-party fees, rather than exact actual amounts; under Electronic Funds Transfer Act and Remittance Rule, providers would have been required to give exact amounts rather than estimates on July 21, 2020.

https://files.consumerfinance.gov/f/documents/cfpb_policy-statement_remittances-covid-19_2020-04.pdf

Nature of Action: Staff Statement. 

Expires: Jan. 1, 2021

CONSUMER FINANCE PROTECTION BUREAU (CFPB)
#6ec066

Date of Action: April 13, 2020

Summary of Action: Relief exempting COVID-19-related government relief stimulus payments from “compulsory use prohibition” of Reg. E, i.e. the rule that prohibits government agencies from requiring that consumers establish accounts with a particular financial institution for receipt of electronic transfers as a condition for receiving government benefits. The relief is accomplished by excluding COVID-19 relief payments, that meet certain conditions, from the definition of “government benefit.”

https://www.consumerfinance.gov/about-us/newsroom/cfpb-paves-way-consumers-receive-economic-impact-payments-quicker/

Nature of Action: Interpretive rule. 

Expires: No explicit expiration date, but rule only applies to COVID-19 related payments.

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 13, 2020

Summary of Action: Provides relief for funds and investment advisers from requirements for in-person board meetings and certain filing deadlines.  

https://www.sec.gov/news/press-release/2020-63

Nature of Action: Exemptive order. 

Expires: Relief related to in-person board meetings and FORM N-23C-2 expires on June 15, 2020; all other relief expires on April 30, 2020. 

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 16, 2020

Summary of Action: Provides stock exchanges with relief from Consolidated Audit Trail implementation deadlines so that those firms that report into CAT can maintain focus on operational readiness allow them to reduce operational risk. Exchanges announced they would not take disciplinary action against members for failing to meet deadlines following announcement of SEC relief.

https://www.sec.gov/divisions/marketreg/mr-noaction/2020/consolidated-audit-trail-reporting-031620.pdf

Nature of Action: No-action letter. 

Expires: May 20, 2020

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 19, 2020

Summary of Action: Provides relief allowing affiliates of money market funds to purchase securities from those funds without complying with the provisions of Rule 17a-9 that conflict with banking regulations affiliates are subject to. 

https://www.sec.gov/investment/investment-company-institute-031920-17a

Nature of Action: No-action letter. 

Expires: Expires upon notice of staff. 

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 20, 2020

Summary of Action: Provides temporary relief for transfer agents from certain reporting and record-keeping requirements, as well as requirement for transfer agents, exchanges, BDs, clearing agencies, securities information processors, and national securities associations to submit fingerprints of officers and directors to DOJ.

https://www.sec.gov/rules/exorders/2020/34-88448.pdf

Nature of Action: Exemptive order. 

Expires: May 30, 2020

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 23, 2020

Summary of Action: Permits mutual funds (but not money market funds) to borrow from affiliated entities/sponsors. 

https://www.sec.gov/news/press-release/2020-70

Nature of Action: Exemptive order. 

Expires: June 30, 2020

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 24, 2020

Summary of Action: Relief from Rule 302(b) of Reg. S-T requiring a manually signed signature form to accompany electronic filings, executed at or before the time of the electronic filing; relief allows signatories to provide manually signed signature page to filer “as promptly as reasonably practicable.” 

https://www.sec.gov/corpfin/announcement/staff-statement-regarding-rule-302b-regulation-s-t-light-covid-19-concerns

Nature of Action: Staff no-action statement. 

Expires: No expiration given. 

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 25, 2020

Summary of Action: Provides relief to mutual funds from delivery of prospectuses or holding in-person board meetings for mutual funds or business development companies.

https://www.sec.gov/rules/other/2020/ic-33824.pdf

Nature of Action: Exemptive order. 

Expires: June 30, 2020, for relief related to in-person board meetings and FORM N-23C-2 and Aug. 15, 2020, for all other relief.

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 25, 2020

Summary of Action: Broad exemption to permit delayed filings of proxy materials with the Commission.

https://www.sec.gov/rules/exorders/2020/34-88465.pdf

Nature of Action: Exemptive order. 

Expires: Periods covering March 1, 2020 - July 1, 2020. 

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 25, 2020 (supersedes original relief granted March 4, 2020). 

Summary of Action: Gives certain public companies an additional 45 days to file disclosure reports that would have been due between March 1 and July 1, 2020. 

https://www.sec.gov/news/press-release/2020-53

Nature of Action: Exemptive order. 

Expires: July 1, 2020. Companies have an additional 45 days from original due date to make filings.

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 25, 2020 

Summary of Action: Guidance on disclosures in light of COVID-19, including disclosure of risks associated with COVID-19 and reporting of earnings and financial results.

https://www.sec.gov/corpfin/coronavirus-covid-19   

Nature of Action: Staff guidance. 

Expires: No expiration given. 

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 25, 2020

Summary of Action: Temporary relief from provisions of Rule 606, specifically:

  • Broker-dealers are exempt from the requirement to provide the public report covering the first quarter of 2020 required by Rule 606(a) until May 29, 2020;
  • Broker-dealers that engage in outsourced routing activity are exempt from the requirement to collect the monthly customer-specific data required by Rule 606(b)(3) for such activity until June 1, 2020, and are exempt until July 29, 2020, from the requirement to provide a customer-specific report of June 2020 outsourced routing data within seven business days for customer requests for such customer-specific reports that are made on or before July 17, 2020.

https://www.sec.gov/rules/exorders/2020/34-88478.pdf  

Nature of Action: Temporary exemptive order. 

Expires: Deadline for BDs to provide Rule 606(a) public report is May 29, 2020; BDs do not have to collect 606(b)(3) data until June 1, 2020, and are exempt until July 29, 2020 from providing data in response to customer request made on or before July 17, 2020.

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 25, 2020 

Summary of Action: Temporary relief from filing deadlines, for issuers using Reg. A or Reg. Crowdfunding, to file required reports or forms where the deadline is May 31, 2020, and the filer files the required report within 45 days from the original deadline.

https://www.sec.gov/rules/interim/2020/33-10768.pdf

Nature of Action: Temporary final rule.  

Expires: Applies where filing deadline is May 31, 2020, or earlier; filer has additional 45 days to file.

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 25, 2020 

Summary of Action: Relief from filing deadline for municipal advisor’s annual update to Form MA; if form was due on June 30 or earlier, if the filer files within 45 days after the original due date for the filing.

https://www.sec.gov/rules/exorders/2020/34-88491.pdf

Nature of Action: Temporary exemptive order.  

Expires: Applies where filing deadline is June 30, 2020, or earlier; filer has additional 45 days to file.

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 25, 2020 

Summary of Action: Allows affiliates of an open-end registered investment company that does not hold themselves out as a money market fund (and that is not an exchange-traded fund) to take advantage of provisions of Rule 17a-9 that provide exemptions from Investment Act Section 17(a) prohibitions of affiliated purchases; Rule 17a-9 exemptions, by their terms, only apply to affiliates of money market funds.

https://www.sec.gov/investment/investment-company-institute-032620-17a

Nature of Action: Staff no-action letter.  

Expires: Until further notice from staff. 

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: March 26, 2020 

Summary of Action: Temporarily allows those who want to gain access to filing through EDGAR system to do so without first obtaining notarization.

https://www.sec.gov/news/press-release/2020-74

Nature of Action: Exemptive order.  

Expires: July 1, 2020

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: April 2, 2020 

Summary of Action: Staff will not recommend enforcement action for failure to comply with requirements relating to submission of paper documents, provided impacted filers discuss with SEC staff appropriate measures, take appropriate steps to electronically file documents, and maintain paper copies as appropriate.

https://www.sec.gov/tm/paper-submission-requirements-covid-19

Nature of Action: Staff statement.  

Expires: June 30, 2020

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: April 8, 2020 

Summary of Action: Temporary and conditional relief for Business Development Companies to invest beyond their asset coverage requirements and permits them to co-invest with affiliated funds.

https://www.sec.gov/news/press-release/2020-84

Nature of Action: Exemptive order.  

Expires: Dec. 31, 2020

U.S. SECURITIES AND EXCHANGE COMMISSION (SEC)
#4396ca

Date of Action: April 10, 2020 

Summary of Action: Relief from requirement to file hard copy of Form 144, provided that a form is submitted via email with appropriate signatures and the filer maintains a hard copy, among other requirements.

https://www.sec.gov/corpfin/announcement/form-144-paper-filings-email-option

Nature of Action: Staff statement.  

Expires: June 30, 2020

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 17, 2020

Summary of Action: Provides relief from Rule 1.35 requirement to time-stamp orders, if personnel responsible for making records is required to be absent, provided that record of date and time to the nearest minute is otherwise created pursuant to Rule 1.35.

https://www.cftc.gov/PressRoom/PressReleases/8132-20

Nature of Action: No action letter.  

Expires: June 30, 2020

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 17, 2020

Summary of Action: Provides relief for floor brokers from requirements to make and keep records of oral communications, to time-stamp orders, to be physically present on the trading floor, and to register as an Introducing Broker, in light of potential personnel absences and other disruptions due to COVID-19. 

https://www.cftc.gov/PressRoom/PressReleases/8132-20

Nature of Action: No action letter.  

Expires: June 30, 2020

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 17, 2020

Summary of Action: Relief for foreign exchange dealers from requirements to make and keep records of oral communications and to time-stamp orders, in light of potential personnel absences and other disruptions due to COVID-19. 

https://www.cftc.gov/PressRoom/PressReleases/8132-20

Nature of Action: No action letter.  

Expires: June 30, 2020

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 17, 2020

Summary of Action: Relief for swap dealers, introducing brokers, and futures commission merchants, from requirements to make and keep records of oral communications and time-stamp orders. Also gives an additional 30 days to provide CCO reports in light of potential personnel absences and other disruptions due to COVID-19. 

https://www.cftc.gov/PressRoom/PressReleases/8132-20

Nature of Action: No action letter.  

Expires: June 30, 2020. CCO deadline is extended for 30 days for any report due before Sept. 1, 2020. 

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 17, 2020

Summary of Action: Relief for Designated Contract Markets from audit-trail and related requirements under CEA sections 5(d)(4) and (10) and CFTC regulations in light of potential disruptions due to COVID-19. 

https://www.cftc.gov/PressRoom/PressReleases/8133-20

Nature of Action: No action letter.  

Expires: June 30, 2020 

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 17, 2020

Summary of Action: Relief for SEFs from requirements related to audit trail, trade monitoring, trade reconstruction, and recordkeeping, to the extent compliance is affected by inability to record voice communications because of personnel displacement. 

https://www.cftc.gov/PressRoom/PressReleases/8133-20

Nature of Action: No action letter.  

Expires: June 30, 2020 

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 17, 2020

Summary of Action: Relief for SEFs from filing deadlines to submit CCO annual reports and fourth-quarter financial reports. The relief applies if the reports were required to be filed before Sept. 1, 2020; the reports must be filed within 120 days from the end of the SEF’s fiscal year.

https://www.cftc.gov/PressRoom/PressReleases/8133-20

Nature of Action: No action letter.  

Expires: Relief applies to reports due before Sept. 1, 2020; SEF has 120 days from end of fiscal year to submit reports. 

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 20, 2020

Summary of Action: Relief for a “major” insured-depository institution from counting swaps whose underlying commodity is crude oil, natural gas or natural gas liquids, toward the “aggregate uncollateralized outward exposure” for purposes of determining whether the IDI is a “major swap participant.” To qualify for relief, the swap must also be excluded from the de minimis calculation pursuant to the exclusion for swaps entered in connection with originating loans to IDI customers. The CFTC justifies the relief because of the unprecedented drop in oil prices, causing the AUOE of the requesting IDI to increase significantly.

https://www.cftc.gov/PressRoom/PressReleases/8136-20

Nature of Action: No action letter.  

Expires: Sept. 30, 2020.  

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 20, 2020

Summary of Action: Relief for commodity pool operators from filing deadlines for Form CPO-PQR, Pool Annual Reports and Pool Periodic Account Statements.

https://www.cftc.gov/PressRoom/PressReleases/8136-20

Nature of Action: No-action letter.  

Expires: CPO-PQR deadline for small- or mid-sized CPOs is May 15; CPO-PQR deadline for large CPOs is July 15; Pool Annual Reports due before April 30, 2020, are due within 45 days after the due date; Pool periodic account statements for all reporting periods ending on or before April 30, 2020, must be distributed within 45 days of the end of the reporting period.

OCC, FRB, FDIC
#c19fca

Date of Action: March 27, 2020

Summary of Action: Allows early adoption of SA-CCR, i.e. a new “more risk-sensitive measurement of the exposure amounts of derivative contracts.” Effective date of the SA-CCR final rule was April 1, 2020; banks would have been able to use the framework then (advanced approaches banks are required to adopt the framework by Jan. 1, 2022), this rule allows them to use the framework for 1Q 2020 reporting. 

https://www.federalregister.gov/documents/2020/03/31/2020-06755/standardized-approach-for-calculating-the-exposure-amount-of-derivative-contracts.

Nature of Action: Notification of change in effective date.  

Expires: No expiration given. 

COMMODITY FUTURES TRADING COMISSION (CFTC)
#c19fca

Date of Action: March 27, 2020

Summary of Action: Allows foreign affiliates of FCMs, that are exempt from registration as FCMs by virtue of CFTC Rule 30.5, to accept orders from U.S. person for execution on U.S. contract markets, without requiring the foreign affiliate to be registered as an Introducing Broker.

https://www.cftc.gov/PressRoom/PressReleases/8142-20

Nature of Action: No action letter.  

Expires: Sept. 30, 2020