Although the CFTC has not completed writing the registration requirements (and, therefore, has not set a date by which registration must be completed), National Futures Association (NFA) has prepared this brief summary of the current proposed forex registration requirements to give firm and individual applicants a basic understanding of the registration process.

Completed Online Registration Forms:
Applicants must file a completed 7-R form through NFA's Online Registration System (ORS). NFA has published an ORS Users Guide and a tutorial on its Web site that provide step-by-step instruction for the most common registration tasks.

Additional Requirements for Introducing Brokers:
Applicants registering as Independent Introducing Brokers must also submit a Form 1-FR-IB (Part A) or FOCUS Report. Independent IBs must maintain a minimum net capital of $45,000 at all times.

Applicants registering as Guaranteed Introducing Brokers must submit a completed Guarantee Agreement (Form 1-FR-IB Part B) from a Forex Dealer Member (FDM).

Additional Requirements for Commodity Trading Advisors and Commodity Pool Operators:
Before they can begin soliciting customers, CTAs and CPOs must submit a Disclosure Document to NFA for approval. The Disclosure Document must be completed in accordance with NFA Compliance Rule 2-41.

Proficiency Exams:
All individuals who solicit retail off-exchange forex business or who supervise that activity will be required to take and pass the National Commodity Futures Examination (NCFE or Series 3). In addition, applicants will be required to take and pass a new exam, Series 34. This hour-long exam consists exclusively of forex-related questions. NFA has published Study Guides for both exams in the Registration section of its Web site (www.nfa.futures.org).

Both exams are currently available and are administered by the Financial Industry Regulatory Authority (FINRA). The testing application form (U10) can either be downloaded or completed online at www.finra.org.

NFA has proposed to the CFTC that individuals who were approved sole proprietor principals or registered as associated persons or floor brokers on May 22, 2008, be exempt from taking the Series 34 exam. However, to date, the CFTC has not ruled on this proposal.

Fingerprint Cards:
NFA requires all individual applicants to submit fingerprint cards, which are sent to the Federal Bureau of Investigation (FBI) to determine if the applicant has a criminal record. NFA can only accept and process a complete FBI "applicant card". These cards are available by contacting NFA's Information Center at 800-621-3570. Applicants are encouraged to submit more than one set of fingerprints with their application to avoid delays in obtaining additional sets if necessary for processing.

NFA offers a fingerprinting service for NFA applicants at the Chicago office (300 South Riverside Plaza, Suite 1800) between the hours of 8:30 a.m. and 4:00 p.m. for $15 (cash, check or money order). In order to use NFA's fingerprint service, visitors must be pre-registered in the building's visitor registry. Visitors should contact NFA's Information Center (either by phone at 312-781-1410 or send an email to information@nfa.futures.org) to register their name and date of visit so they can receive access to NFA's offices on the 18th floor. NFA recommends that visitors pre-register at least a day prior to their visit.

All individuals being fingerprinted will be required to present two forms of identification, one of which is a valid picture ID issued by a government agency, in order to verify the identity of the person being fingerprinted. NFA now submits digital images of fingerprints to the FBI for criminal background checks. Results are received in three days or less, and in some cases within several hours, resulting in a faster and more efficient registration process.

CFTC Registration Fees:
$200 non-refundable registration fee for each IB, CTA or CPO
$85 non-refundable registration fee for each principal and/or AP of an IB, CTA or CPO

NFA Membership Dues:
$750 non-refundable annual dues for each IB, CTA or CPO

This brief overview is not intended to provide a comprehensive guide to CFTC registration. For additional information, visit NFA's Web site at www.nfa.futures.org or contact NFA's Information Center at (800) 621-3570 from 8:00 a.m. to 5:00 p.m. CT Monday through Friday.

November 7, 2008