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August 27, 1998
Ms. Jean A. Webb
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, D.C. 20581
RE: National Futures Association: Proposed Amendments to Registration Rules 201 and 501(a)*
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 Registration Rules 201 and 501(a). The proposals contained herein were approved by NFA's Board of Directors ("Board") on August 20, 1998.
NFA intends to make the proposed amendments 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. NFA will not initiate any action until the Commission issues a delegation order authorizing NFA to take adverse registration actions against Agricultural Trade Option Merchants ("ATMs"), ATM associated persons ("APs") and applicants for registration as ATMs or ATM APs.
Please be advised that the language contained herein also reflects amendments to Registration Rule 201 that are currently pending Commission approval. Should those amendments still be pending when the proposals in this submission letter become effective, the pending amendments will not be reflected in the revised rule.
Daniel J. Roth
cc: Chairman Brooksley Born
Commissioner Barbara Pedersen Holum
Commissioner John E. Tull, Jr.
Commissioner David D. Spears
Geoffrey Aronow, Esq.
I. Michael Greenberger, Esq.
Alan L. Seifert, Esq.
Lawrence B. Patent, Esq.
David Van Wagner, Esq.
*The amendments to these rules became effective on September 7, 1998 under the "10-day" effective date provision of Section 17(j) of the Commodity Exchange Act. However, NFA will not initiate any adverse registration actions against ATMs or their APs until NFA receives from the Commission a delegation order authorizing NFA to take such actions.