Rule Submissions to the CFTC

August 22, 2005

Via Federal Express

Ms. Jean A. Webb
Secretariat
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, DC 20581

Re: National Futures Association: Proposed Adoption of Compliance Rule 2-39 and Proposed Amendments to Compliance Rule 2-36, Financial Requirements Sections 11 and 12, and the Interpretive Notice Regarding Forex Transactions With Forex Dealer Members*

Dear Ms. Webb:

By letter dated March 7, 2005, National Futures Association ("NFA") submitted to the Commodity Futures Trading Commission ("CFTC" or "Commission") for its review and approval a proposed new Compliance Rule 2-39 and proposed amendments to Compliance Rule 2-36, Financial Requirements Sections 11 and 12, and the Interpretive Notice regarding Forex Transactions with Forex Dealer Members. NFA has corrected certain computation errors in the Interpretive Notice and is resubmitting these proposals for the Commission's review and approval.

PROPOSED RULE AMENDMENTS

EXPLANATION OF PROPOSALS

NFA respectfully requests that the Commission review and approve the proposed adoption of Compliance Rule 2-39 and proposed amendments to Compliance Rule 2-36, Financial Requirements Sections 11 and 12, and the Interpretive Notice regarding Forex Transactions with Forex Dealer Members.

Respectfully submitted,

Thomas W. Sexton
Vice President and General Counsel