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September 09, 2004

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 Interpretive Notice to NFA Bylaw 1101 and Compliance Rules 2-9 and 2-29 Entitled Guidelines Relating to the Registration of Third-Party Trading System Developers and the Responsibility of NFA Members for Promotional Material That Promotes Third-Party Trading System Developers and Their Trading Systems*

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") a proposed Interpretive Notice to NFA Bylaw 1101 and Compliance Rules 2-9 and 2-29 entitled Guidelines Relating to the Registration of Third-Party Trading System Developers and the Responsibility of NFA Members for Promotional Material That Promotes Third-Party Trading System Developers and Their Trading Systems. This proposal was approved by NFA's Board of Directors ("Board") on August 19, 2004. NFA respectfully requests Commission review and approval of the proposed interpretive notice.

PROPOSED RULE AMENDMENTS

EXPLANATION OF PROPOSALS

NFA respectfully requests that the Commission review and approve the proposed Interpretive Notice contained herein.

Respectfully submitted,
Thomas W. Sexton
Vice President and General Counsel


* The proposed addition of Interpretive Notice to NFA Bylaw 1101 and Compliance Rules 2-9 and 2-29 Entitled Guidelines Relating to the Registration of Third-Party Trading System Developers and the Responsibility of NFA Members for Promotional Material That Promotes Third-Party Trading System Developers and Their Trading Systems became effective on January 10, 2005.

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