COVID-19: US Regulatory Relief and Related Effects on Markets and Participants

Morgan Lewis

The US Securities and Exchange Commission, Financial Industry Regulatory Authority, Commodity Futures Trading Commission, and National Futures Association have each announced temporary regulatory relief for market participants whose operations may be affected by the coronavirus (COVID-19) pandemic.

We have created a chart summarizing the available relief from certain requirements of the Investment Company Act of 1940, as amended (the 1940 Act); the Investment Advisers Act of 1940, as amended (the Advisers Act); the Securities Exchange Act of 1934, as amended (the 1934 Act); the Securities Act of 1933, as amended (the 1933 Act); the Commodity Exchange Act (CEA), as amended; and the rules and regulations thereunder, as well as Financial Industry Regulatory Authority (FINRA) and National Futures Association (NFA) rules.

These actions are the latest in a series of steps taken by the US Securities and Exchange Commission (SEC), the Commodity Futures Trading Commission (CFTC), FINRA, and the NFA to address various ongoing market effects related to COVID-19 and associated disruptions. We expect these agencies and self-regulatory organizations to continue to monitor and implement further relief measures and to extend the duration of current measures as needed. We will endeavor to keep this chart current so as to reflect any such developments.

See the chart on available US regulatory relief >>

Coronavirus COVID-19 Task Force

For our clients, we have formed a multidisciplinary Coronavirus COVID-19 Task Force to help guide you through the broad scope of legal issues brought on by this public health challenge, which includes a Financial Services COVID-19 Task Force to focus on the issues specifically impacting our financial services industry clients.

We also have launched a resource page to help keep you on top of developments as they unfold. More detailed information about certain of the relief summarized below can be found in the Financial Services section of our COVID-19 resource page.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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