Associated Persons from the Fingerprinting Requirements. On June 21st, the CFCT's Division of Swap Dealer and Intermediary Oversight issued a no-action letter responding to a request from the National Futures Association for relief from the fingerprinting requirement for associated persons of CFTC registrants where the associated persons have not resided in the United States since reaching 18 years of age. The no-action letter provides that DSIO will not recommend that the Commission commence an enforcement action against a sponsoring FCM, RFED, IB, CPO, CTA, or leverage transaction merchant based solely upon the failure to submit a fingerprint card with a Form 8-R on behalf of a Non-U.S. Associated Person, provided that the sponsoring FCM, RFED, IB, CPO, CTA, or leverage transaction merchant: (1) submits a Form 8-R for each Non-U.S. Associated Person with a "certification" that includes certain information; and (2) notifies NFA within 30 days after the filing of a Form 8-R that it has not submitted a fingerprint card for each Non-U.S. Associated Person. CFTC Letter No. 13-29; CFTC Press Release.