While the interpretive notice applies to all current registrants, it presently states that new registrants can qualify by training only if they are registered within six months after the first retail, exchange-traded security futures contract begins trading. At the time the interpretive notice was adopted, NFA staff assumed that six months, or until May 8, 2003, would provide adequate time to update both the futures and the securities examinations. NFA staff has been diligently working to revise the Series 3 and Series 30 examinations and can have them available by the May 8 deadline. NASD, however, has recently informed NFA that its examinations will not be available until January 2004.
Although NFA is prepared to meet the May 8 deadline, we are concerned about the regulatory disparity that may occur if we incorporate security futures questions into our proficiency examinations before the securities industry does. For that reason, we propose postponing the changes to the Series 3 and Series 30 examinations until January 2004, although we will implement them earlier if NASD does so. We have discussed this matter with SEC staff and they agree that we can coordinate with NASD.
The current version of the interpretive notice incorporates the May 8 deadline through its references to a date six months after security futures begin trading. The revised interpretive notice extends the training option to all new registrants who take the Series 3 and apply for registration before the revised examination becomes available. The revised interpretive notice was similarly changed for designated security futures principals.