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May 27, 2011
Mr. Greg Tanzer
Re: Public Comment on the Principles on Suspensions of Redemptions in Collective Investment Schemes Consultation Report
Dear Mr. Tanzer:
National Futures Association (NFA) appreciates the opportunity to comment on the IOSCO Technical Committee's Principles on Suspensions of Redemptions in Collective Investment Schemes (CISs) Consultation Report. NFA is a registered futures association under the U.S. Commodity Exchange Act (CEA) and an affiliate member of IOSCO. NFA is the industry-wide self-regulatory body for the U.S. futures industry and regulates the activities of close to 4,000 member firms and approximately 53,000 registered account executives who work for those firms.
One of NFA's responsibilities is to monitor the regulatory requirements for registered commodity pool operators (CPOs) and their non-exempt commodity pools. We work closely with the U.S. Commodity Futures Trading Commission (CFTC) to provide effective and efficient regulation that protects customers without imposing undue burdens on the futures industry. Over 1,200 CPOs are registered with the CFTC, and the vast majority are NFA Members.
As stated in the Introduction, the principles generally cover all CISs which offer a continuous redemption right. Chapter 2 further states that investors in open-ended CISs expect to be able to redeem on a regular and continuous basis. Additionally, the narrative accompanying proposed principle 7 refers to CISs as open-ended funds that offer redemption on a continuous basis. Therefore, it appears that the proposed principles outlined in this report would not apply to CISs that offer periodic redemption rights. NFA recommends in order to avoid any ambiguity in this area it may be helpful to clearly state that the principles do not apply to CISs with periodic redemption rights.
If you have any questions concerning this letter, please contact me at firstname.lastname@example.org.
Karen K. Wuertz