Key takeaways

• The CFTC has proposed rules to provide an alternative for foreign natural persons who are required to provide fingerprint cards in applications for CFTC registration.
• The proposed rules would allow the registered firm of such foreign natural persons to complete a criminal history background check in lieu of submitting fingerprint cards.
• The proposed rules would expand the current exemptive relief provided by two CFTC no-action letters, and if adopted, would supersede the no-action letters.