On October 6, the National Futures Association (NFA) issued Notice I-20-37 to announce changes to the no-action relief that had previously been issued relating to fingerprinting requirements for applicants for registration as an associated person (AP) and natural person principals of an applicant or registrant found at NFA Registration Rules 204(a)(2)(A) and 206(a)(1)(A). The NFA’s action follows a decision by the Commodity Futures Trading Commission’s (CFTC) Division of Swap Dealer and Intermediate Oversight (Division) that the Division would not extend beyond September 30, parallel no-action relief from the fingerprinting requirements set out in CFTC Regulations 3.10(a)(2) and 3.12(c)(3). (For additional information regarding this no-action relief, please refer to the July 24, 2020 edition of Corporate & Financial Weekly Digest.)

Effective October 1, therefore, all applicants for AP registration and all natural persons listed as a principal of an applicant or registrant must comply with the fingerprinting requirement. Additionally, all persons currently relying on the now-expired no-action relief, as well as APs that have been granted a temporary license, must submit a fingerprint card to the NFA by November 2.

Notice I-20-37 is available here.