CFTC Rule Submissions

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March 07, 2005

Via Federal Express

Ms. Jean A. Webb
Secretariat
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, DC 20581

Re: National Futures Association: Proposed Adoption of Compliance Rule 2-39 and Proposed Amendments to Compliance Rule 2-36, Financial Requirements Sections 1, 11 and 12 and the Interpretive Notice Regarding Forex Transactions With Forex Dealer Members

Dear Ms. Webb:

Pursuant to Section 17(j) of the Commodity Exchange Act ("CEA"), as amended, National Futures Association ("NFA") hereby submits to the Commodity Futures Trading Commission ("CFTC" or "Commission") the proposed adoption of Compliance Rule 2-39 and proposed amendments to Compliance Rule 2-36, Financial Requirements Sections 1, 11 and 12 and the Interpretive Notice regarding Forex Transactions with Forex Dealer Members. These proposals were approved by NFA's Board of Directors ("Board") on February 17, 2005. NFA respectfully requests Commission review and approval of the proposed amendments.

PROPOSED RULE AMENDMENTS

EXPLANATION OF PROPOSALS

NFA respectfully requests that the Commission review and approve the proposed adoption of Compliance Rule 2-39 and proposed amendments to Compliance Rule 2-36, Financial Requirements Sections 1, 11 and 12 and the Interpretive Notice regarding Forex Transactions with Forex Dealer Members.

Respectfully submitted,

Thomas W. Sexton
Vice President and General Counsel

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