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

April 09, 2020

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. If you would like to receive a daily digest of all new updates to the page, please subscribe now to receive our COVID-19 alerts.


If you have any questions or would like more information on the issues discussed in this LawFlash, please contact any of the following Morgan Lewis lawyers:

Marion Giliberti Barish
Lea Anne Copenhefer
Richard A. Goldman
Barry N. Hurwitz
Roger P. Joseph
Jeremy B. Kantrowitz
Gerald J. Kehoe
Daniel A. Losk
Paul B. Raymond
Toby R. Serkin
Stephen C. Tirrell

Washington, DC
Gregg S. Buksbaum
Laura E. Flores
Thomas S. Harman
W. John McGuire
Christopher D. Menconi
Courtney C. Nowell
Steven W. Stone

Sean Graber
Timothy W. Levin
John J. O’Brien

New York
Christopher J. Dlutowski
Christine M. Lombardo
Elizabeth L. Belanger
Jedd H. Wider
Joseph D. Zargari

Michael M. Philipp

Orange County
Jarrod A. Huffman
Laurie A. Dee
Jonathan J. Nowakowski

Ethan W. Johnson

Carrie J. Rief

San Francisco
Peter M. Phleger