CFTC/NFA Registrant PPP Guidance Apr 24, 2020 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.