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March 07, 2000

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 Proposed Amendments of NFA Compliance Rule 2-35 and Adoption of Interpretive Notice to Compliance Rule 2-35 Concerning CPO Profile Documents*

Dear Ms. Webb:

By letter dated September 10, 1998, National Futures Association ("NFA") submitted to the Commodity Futures Trading Commission ("Commission" or "CFTC") for its review and approval proposed amendments to NFA Compliance Rule 2-35. NFA hereby substitutes the previously submitted text of Rule 2-35 with the text set forth herein. Furthermore, NFA hereby submits a proposed new Interpretive Notice to Rule 2-35 concerning CPO Profile Documents. The proposals contained herein were approved by NFA's Board of Directors on February 17, 2000. NFA respectfully requests Commission review and approval of these proposals.

Proposed Amendments of NFA Compliance Rule 2-35

Proposed New Interpretive Notice Relating to CPO Profile Documents: Compliance Rule 2-35

Explanation of Resubmitted Proposed Amendments to NFA Compliance Rule 2-35 and Proposed New Interpretive Notice

NFA respectfully requests that the Commission review and approve the proposals contained herein and also requests that they be declared effective upon Commission approval.

Respectfully submitted,

Daniel J. Roth
Executive Vice President and General Counsel

cc: Chairman William J. Rainer
Commissioner Barbara Pedersen Holum
Commissioner David D. Spears
Commissioner James E. Newsome
Commissioner Thomas J. Erickson
Phyllis J. Cela, Esq.
John C. Lawton, Esq.
Alan L. Seifert, Esq.
David Van Wagner, Esq.
Riva Spear Adriance, Esq.


* The proposed amendments to NFA Compliance Rule 2-35 and the Adoption of Interpretive Notice to Compliance Rule 2-35 Concerning CPO Profile Documents became effective on November 1, 2000.

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