CFTC Rule Submissions

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August 15, 2002

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 Interpretive Notices Regarding Proficiency Requirements and Risk Disclosure for Security Futures Products

Dear Ms. Webb:

Pursuant to Section 17(j) of the Commodity Exchange Act, as amended ("the Act"), National Futures Association ("NFA") hereby submits to the Commodity Futures Trading Commission ("CFTC" or "Commission") the proposed adoption of an Interpretive Notice to NFA Compliance Rules 2-7 and 2-24 and Registration Rule 401: Proficiency Requirements for Security Futures Products and an Interpretive Notice to NFA Compliance Rule 2-30(b): Disclosure Statement for Security Futures Products. Similar versions of the proposed interpretive notices were approved by NFA's Board of Directors ("Board") at its November 15, 2001 meeting. At that meeting, the Board authorized NFA's Executive Committee to make additional changes that may be requested by the CFTC or the Securities and Exchange Commission ("SEC"). The final versions of the interpretive notices, as reflected in this submission, were approved by the Executive Committee on August 13, 2002 and ratified by NFA's Board at its August 15, 2002 meeting.

NFA is invoking the "ten-day" provision of Section 17(j) of the Act for both interpretive notices and shall make the interpretive notice concerning proficiency requirements effective ten days after receipt of this submission by the Commission unless the Commission notifies NFA that the Commission has determined to review the interpretive notice for approval. NFA intends to make the interpretive notice concerning risk disclosure effective ten days after receipt of this submission by the Commission or when the disclosure statement is finalized, whichever is later.

Proposed Interpretive Notice Concerning Proficiency Requirements

Proposed Interpretive Notice Concerning Risk Disclosure

Explanation of Proposed Interpretive Notices

As mentioned earlier, NFA is invoking the "ten-day" provision of Section 17(j) of the Act and shall make the interpretive notice concerning proficiency requirements effective ten days after receipt of this submission by the Commission unless the Commission notifies NFA that the Commission has determined to review the interpretive notice for approval. NFA intends to make the interpretive notice concerning risk disclosure effective ten days after receipt of this submission by the Commission or when the disclosure statement is finalized, whichever is later.

Sincerely,

Thomas W. Sexton
Vice President and General Counsel

cc: Chairman James E. Newsome
Commissioner Barbara Pedersen Holum
Commissioner Thomas J. Erickson
Commissioner Sharon Brown-Hruska
Commissioner Walt Lukken
John C. Lawton, Esq.
Gregory Mocek, Esq.
Patrick J. McCarty, Esq.
Jane Kang Thorpe, Esq.
David Van Wagner, Esq.
Riva Spear Adriance, Esq.

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