Apr 24, 2020 The following was distributed by NFA. Please contact Turnkey for any assistance you may need recalculating your net capital position due to any government stimulus programs related to Covid-19. April 23, 2020 Notice to Members I-20-19 Coronavirus (COVID-19) Update—Regulatory Relief for FCMs and IBs On April 23, 2020, the CFTC issued a no-action letter to futures commission merchants (FCM) and introducing brokers (IB) addressing the net capital treatment of covered loans obtained under the Paycheck Protection Program (PPP) and unpaid FINRA assessment fees. PPP is a component of the Coronavirus Aid, Relief, and Economic Security Act administered by the Small Business Association. Subject to several conditions, the no-action letter permits any FCM or IB that receives a PPP-covered loan to add back to its capital the eligible forgivable expense amount under the PPP when computing adjusted net capital under CFTC Regulation 1.17. The letter also permits any FCM or IB that is an SEC registered broker-dealer and qualifies as a small firm (under FINRA By-laws) to add back to its capital, when computing adjusted net capital under CFTC Regulation 1.17, the amount of any accrued and unpaid FINRA 2020 annual assessments permitted to be deferred by FINRA’s guidance. As discussed below, NFA is issuing similar relief from NFA requirements for FCM and IB Members that are in compliance with the terms of the CFTC’s no-action relief. FCM Net Capital Requirements under NFA Financial Requirements Section 1 NFA Financial Requirements Section 1 requires FCM Members to maintain a minimum level of adjusted net capital as defined in CFTC Regulation 1.17. FCM Members that are in compliance with the terms of the CFTC’s no-action relief regarding calculating adjusted net capital, will be deemed to be in compliance with NFA’s related requirements. Independent IB Net Capital Requirements under NFA Financial Requirements Section 5 NFA Financial Requirements Section 5 requires each independent IB Member to maintain a minimum level of adjusted net capital as defined in CFTC Regulation 1.17. IB Members that are in compliance with the terms of the CFTC’s no-action relief regarding calculating adjusted net capital, will be deemed to be in compliance with NFA’s related requirements.