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May 15, 2012
Mr. Mohamed Ben Salem
Re: Public Comment on the Principles for the Valuation of Collective Investment Schemes Consultation Report
Dear Mr. Salem:
National Futures Association (NFA) appreciates the opportunity to comment on the IOSCO Technical Committee's Principles for the Valuation of 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. Approximately 1,200 CPOs are registered with the CFTC, and the vast majority are NFA Members.
NFA suggests the following language to clarify footnote 8 on page 9:
"In the context of this paper, CIS does not include a CIS for which a regulatory structure establishes registration and regulatory requirements for the person operating a CIS rather than the CIS itself."
NFA also suggests eliminating the last sentence in the footnote that refers to "unregulated CIS" as this does not accurately reflect the regulatory oversight scheme for the entities described in this footnote.
If you have any questions concerning this letter, please contact me at firstname.lastname@example.org.
Karen K. Wuertz