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Proposed Rule

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EXPLANATION OF PROPOSED AMENDMENTS

On August 17, 2007, NFA submitted a new interpretive notice to Compliance Rule 2-4 governing trade secrets and proprietary information to the CFTC and the SEC. The submission indicated that NFA intended to make the interpretive notice effective ten days after the CFTC received it unless the CFTC informed NFA that it wanted to review the proposal. The CFTC dismissed review, and the interpretive notice became effective on September 5, 2007.

SEC staff subsequently contacted NFA with technical wording changes that do not affect the substance of the interpretive notice. The current amendments adopt this language.

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 the Interpretive Notice to Compliance Rule 2-4 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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