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December 22, 1998

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

Re: National Futures Association: Proposed Amendments to NFA Compliance Rules 3-5, 3-6, 3-7, 3-8, and 3-11 and Proposed Adoption of NFA Compliance Rule 3-18*

Dear Ms. Webb:

Pursuant to Section 17(j) of the Commodity Exchange Act, as amended, National Futures Association ("NFA") hereby submits to the Commodity Futures Trading Commission ("CFTC" or "Commission") proposed amendments to NFA Compliance Rules 3-5, 3-6, 3-7, 3-8, and 3-11 and the proposed adoption of NFA Compliance Rule 3-18. NFA's Board of Directors ("Board") approved the amendments and proposed rule on November 19, 1998.

NFA respectfully requests that the Commission review and approve the proposed amendments and the proposed new rule and also requests that they be declared effective upon Commission approval.

Proposed Amendments and Proposed New Rule

Explanation of Proposed Amendments

Respectfully submitted,

Daniel J. Roth
General Counsel

cc: Chairman Brooksley Born
Commissioner Barbara Pedersen Holum
Commissioner John E. Tull, Jr.
Commissioner David D. Spears
Commissioner James E. Newsome
Geoffrey Aronow, Esq.
I. Michael Greenberger, Esq.
Alan L. Seifert, Esq.
Lawrence B. Patent, Esq.
David Van Wagner, Esq.


*The amendments to these rules became effective on June 17, 1999.

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