Proposed Rule

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PROPOSED AMENDMENTS TO NFA FINANCIAL REQUIREMENTS SECTION 3 AND SCHEDULE D AND PROPOSED ADOPTION OF AN INTERPRETIVE NOTICE CONCERNING FCM AND IB FILING REQUIREMENTS
(Additions are underscored and deletions are bracketed)

FINANCIAL REQUIREMENTS

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SECTION 3. DEBT/EQUITY RATIO REQUIREMENT.

(a) Requirement. Except as provided in (b) below, each Member FCM shall have "Equity Capital" (as defined in Schedule B hereto), inclusive of "Satisfactory Subordination Agreements" (as defined in Schedule C hereto) that qualify as Equity Capital, of not less than 30 percent of the following amount: The Member's Equity Capital plus the outstanding principal amount of Satisfactory Subordination Agreements. [minus the excess of the Member's Adjusted Net Capital (See Schedule A) over the minimum adjusted net capital required under Section 1 above.]

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SCHEDULE D

FINANCIAL REPORTS

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SECTION D2. INTERIM REPORTS. [Each Member FCM must file with its DSRO an interim financial report, on Form 1-FR or other format acceptable to the DSRO, as of a date six months after the date for which the certified financial report is due.] Each Member FCM for which NFA is the DSRO shall [also] file with NFA an interim financial report, on Form 1-FR or other format acceptable on a quarterly basis. (The term "other format acceptable" is used so that FOCUS Reports may be used to fulfill a Member FCM's filing requirements.) For Member FCMs which use the FOCUS Report to fulfill their filing requirements, the interim report requirement is satisfied by the quarterly FOCUS Part II or IIA which under SEC requirements is filed based on the calendar quarter.

D2-a. Due Date. Interim reports must be filed no later than [45] 17 business days after the date for which the report is made, except in those cases where a Member FCM has applied to its DSRO and has received an approval for an extension, or has received a notice from the DSRO that additional time is required to analyze the request, pursuant to D4-d(i) below, in which case this provision does not apply.

INTERPRETIVE NOTICE
FCM AND IB FILING REQUIREMENTS

Effective June 30, 1997, NFA Financial Requirements call for any unaudited financial report filed by an FCM or an IB not operating pursuant to a guarantee agreement to be filed with NFA within 17 business days. In order for FCMs and IBs to become acclimated to the new filing deadlines, the due dates for all unaudited financial reports as of a date from June 30, 1997 through December 31, 1997 will be 30 days after the date of the statement instead of 17 business days. Beginning with unaudited statements dated in 1998 the 17 business day requirement will apply.

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