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January 26, 2006
Via Federal Express
Ms. Jean A. Webb
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, DC 20581
Re: National Futures Association: Resubmission of Proposed Amendments to Financial Requirements Section 1 (to Impose a Capital Requirement on FCMs With Retail Forex Affiliates) and the Interpretive Notice Regarding Forex Transactions with Forex Dealer Members*
Dear Ms. Webb:
On March 7, 2005, National Futures Association ("NFA") originally submitted the above-captioned requirements to the Commodity Futures Trading Commission ("CFTC" or "Commission") for its review and approval. NFA withdrew that submission on August 22, 2005.
Pursuant to Section 17(j) of the Commodity Exchange Act, as amended, NFA hereby resubmits, as modified, the proposed amendments to Financial Requirements Section 1 (to impose a capital requirement on FCMs with retail forex affiliates) and the Interpretive Notice regarding Forex Transactions with Forex Dealer Members. These proposals were approved by NFA's Board of Directors ("Board") on November 17, 2005 and submitted to the Commission for review and approval by letter dated November 29, 2005. This letter now replaces the content of that November 29, 2005 submission letter relating to the above-referenced proposal. NFA respectfully requests Commission review and approval of the proposed amendments.
NFA respectfully requests that the Commission review and approve the proposed amendments to the Financial Requirements Section 1 and the Interpretive Notice regarding Forex Transactions with Forex Dealer Members.
Thomas W. Sexton
Vice President and General Counsel
* The proposed amendments to Financial Requirements Section 1 and the Interpretive Notice Regarding Forex Transactions with Forex Dealer Members become effective on July 31, 2006.