Expiration of Temporary Relief from Fingerprinting Requirements

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.

Relief from the On-Site Annual Inspection of Branch Offices and Guaranteed IBs

Due to COVID-19, NFA understands that it may difficult for Members to conduct on-site inspections at branch offices and guaranteed IBs this year. Therefore, although Members must conduct the required annual inspection of each branch office and guaranteed IB by December 31, 2020, firms may conduct these inspections remotely.

Expiration of Temporary No-Action Relief from the Requirement to Submit a Fingerprint Card with Form 8-R

Given the widespread, if restricted, reopening of businesses and services in most parts of the country, and the availability of law enforcement offices to persons needing to have fingerprints taken, DSIO now believes that the blanket relief provided under Staff Letters 20-16 and 20-20 is no longer urgently needed. Accordingly, that general relief will be permitted to expire September 30.