Rule Submissions to the CFTC

May 15, 1997

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: Proposed Amendments to NFA Compliance Rule 3-3 and NFA Financial Requirements Section 3 and Schedule D, and Proposed Adoption of an Interpretive Notice Concerning FCM and IB Filing 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 NFA Compliance Rule 3-3 and NFA Financial Requirements Section 3 and Schedule D and the proposed adoption of an Interpretive Notice Concerning FCM and IB Filing Requirements. The proposals contained herein were approved by NFA's Board of Directors ("Board") on May 15, 1997.

NFA intends to make the proposals contained herein effective 10 days after receipt of this submission by the Commission unless the Commission notifies NFA within the 10-day period that the Commission has determined to review the amendments for approval.

Proposed Amendments to NFA Compliance Rule 3-3

Proposed Amendments to NFA Financial Requirements Section 3 and Schedule D and Proposed Adoption of an Interpretive Notice Concerning FCM and IB Filing Requirements

Explanation of Proposed Amendments

Sincerely,

Daniel J. Roth
General Counsel

cc: Chairman Brooksley Born
Commissioner Barbara Pedersen Holum
Commissioner Joseph P. Dial
Commissioner John E. Tull, Jr.
Andrea M. Corcoran, Esq.
Geoffrey Aronow, Esq.
Alan L. Seifert, Esq.
Susan E. Ervin, Esq.
Lawrence B. Patent, Esq.
David Van Wagner, Esq.