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EXPLANATION OF PROPOSED AMENDMENTS

NFA Bylaw 707 provides that each member of the Hearing Committee shall serve for a three-year term. NFA Compliance Rule 3-7 provides that the Chairman and remaining members of a disciplinary hearing panel are appointed from among the individuals currently serving on the Hearing Committee. Neither the bylaw nor the rule addresses what happens if the person's term on the Hearing Committee expires while the individual is serving on a hearing panel. Although this has not been a problem to date, in order to avoid legal issues in the future, the amendments to Compliance Rule 3-7 provide that an individual who was appointed to a panel during his or her term on the Hearing Committee can continue serving on that panel when the term expires.

As mentioned earlier, NFA is invoking the "ten-day" provision of Section 17(j) of the Commodity Exchange Act. NFA intends to make the proposed amendments to Compliance Rule 3-7 regarding service on disciplinary hearing panels effective ten days after receipt of this submission by the Commission, unless the Commission notifies NFA that the Commission has determined to review the proposal for approval.

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