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September 10, 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: Resubmission of Probosed Adoption of NFA Compliance Rule 2-35 and Its Interpretive Notice Concerning CPO/CTA Disclosure Documents*

Dear Ms. Webb:

By letter dated January 20, 1998, National Futures Association ("NFA") submitted to the Commodity Futures Trading Commission ("Commission" or "CFTC") for its review and approval the proposed adoption of NFA Compliance Rule 2-35 ("Rule 2-35") and its Interpretive Notice concerning CPO/CTA disclosure documents. NFA hereby substitutes the previously submitted text of Rule 2-35 with the text set forth herein. The text of the proposed Interpretive Notice has not changed since the January 20, 1998 submission and is included herein solely for ease of reference in the Commission's review of proposed Rule 2-35. The amendments to Rule 2-35 contained herein were approved by NFA's Board of Directors ("Board") on August 20, 1998. NFA respectfully requests Commission review and approval of proposed Rule 2-35 and its Interpretive Notice.

Proposed Rule 2-35

Proposed Interpretive Notice to Rule 2-35

Explanation of Proposed Amendments

NFA respectfully requests that the Commission review and approve the proposed adoption of NFA Compliance Rule 2-35 and its Interpretive Notice and requests that they be declared effective as determined by NFA after receiving Commission approval.

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 proposed adoption of NFA Compliance Rule 2-35 and its Interpretive Notice Concerning CPO/CTA Disclosure Documents became effective on April 30, 1999.

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