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November 06, 2006
Via Federal Express
Ms. Eileen A. Donovan
Office of the Secretariat
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, DC 20581
Re: National Futures Association: Proposed Amendments to NFA's Interpretive Notice Regarding FCM and IB AML Program Requirements*
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 the Interpretive Notice regarding FCM and IB AML program requirements. The amendments to the proposed Interpretive Notice were approved by NFA's Board of Directors ("Board") on May 18, 2006. At that meeting, the Board authorized NFA's Executive Committee to make additional changes that may be requested by the CFTC, FinCEN (Treasury), FIA and NIBA. The final version of the Interpretive Notice, as reflected in this submission, was approved by the Executive Committee on October 19, 2006. It is expected that NFA's Board at its next meeting on November 16, 2006 will ratify the Executive Committee's action in approving the amended Notice. 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 Interpretive Notice regarding FCM and IB AML program requirements.
Thomas W. Sexton
Vice President and General Counsel
* The proposed amendments to NFA's Interpretive Notice Regarding FCM and IB AML Program Requirements become effective on November 16, 2006.