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April 29, 1998
Ms. Jean A. Webb
RE: Two-Part Disclosure Documents for Commodity Pools 63 FR 15112
Dear Ms. Webb:
On March 30, 1998, the Commodity Futures Trading Commission ("Commission") published proposed amendments to its regulations which are necessary in order to implement National Futures Association's ("NFA") proposed two-part disclosure document rule. In this Federal Register release, the Commission also requested comment on NFA's proposed rule.
NFA would like to take this opportunity to reiterate the importance of the proposed two-part disclosure document rule. It is a widely held belief that under the current format, disclosure documents are often unnecessarily long and contain too much legal jargon to be easily understood by the average investor. By adopting the two-part format, along with the requirements for plain English, the public will continue to receive the necessary information to make an informed investment decision, but will receive this information in a more concise and readable format.
As described in our submission letter, the development of this rule was a long and intense process, which NFA believes produced a disclosure scheme that will simplify and enhance the disclosure document process. NFA encourages the Commission to add force to its policy statement supporting the principle of two-part documents by approving NFA's rule proposal as quickly as possible.
Daniel J. Roth