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April 22, 2010
Via E-mail: email@example.com
Mr. David A. Stawick
Re: Delegations of Authority to Disclose Confidential Information
Dear Mr. Stawick,
National Futures Association (NFA) appreciates the opportunity to comment on the Commission's proposed amendments to its regulations governing delegations of authority to disclose confidential information. Among other things, the proposed amendments require registered entities to notify the Commission within 10 business days of any deletions or additions to its list of officials authorized to receive confidential disclosure.
As you are aware, the current regulation does not impose a specified time period in which to provide the Commission with deletions and additions to the list. While NFA appreciates the need to keep these lists current to ensure that confidential information is not disclosed to an unauthorized person, NFA is concerned that the 10 business day requirement will impose an unnecessary burden on registered entities. Therefore, NFA respectfully requests that the Commission consider extending the notification time period to 30 calendar days after any deletion. NFA believes that a 30 day requirement strikes the appropriate balance and, at the same time, ensures that the Commission receives timely notification of a registered entity's changes.
Very truly yours,
Thomas W. Sexton