Extending relief to floor brokers, the Commodity Futures Trading Commission (“CFTC”) Division of Market Oversight and Market Participants Division recognized the difficulty of complying with some regulations because of the COVID-19 pandemic. While this no-action letter repeats the CFTC staff’s “expectation that registrants will work to implement technological solutions that permit full compliance with CFTC regulations while working in a remote environment,” it also extends relief to floor brokers and trading floors from restrictions on the location where customer orders may be entered, introducing broker registration, and some real-time market monitoring requirements until September 30, 2021.

This comports with the CFTC staff’s emphasis in earlier letters – such as 20-04, 20-09, 20-19, 20-26, and 21-05 – on permitting remote work while encouraging technologies that permit documented compliance.