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February 26, 1998

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 Deletion of NFA Compliance Rule 2-8(e)(2) and Proposed Amendments to NFA Compliance Rule 2-29(b)(5)*

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") the proposed deletion of NFA Compliance Rule 2-8(e)(2) and proposed amendments to NFA Compliance Rule 2-29(b)(5). The proposals contained herein were approved by NFA's Board of Directors ("Board") on February 19, 1998.

The Board subsequently withdrew the interpretive notice to Compliance Rule 2-29 since most of the issues it addressed have been superseded by changes to Commission rules. However, the Board did not amend Compliance Rule 2-34 or its interpretive notice at that time to include the requirement that rate of return be calculated based on the amount committed to trading. The Board has now amended NFA Compliance Rule 2-29(b)(5) to make that requirement explicit.

The amendment to Compliance Rule 2-29(b)(5) supplements NFA's March 15, 1995 submission regarding NFA Compliance Rule 2-34 and its accompanying interpretive notice. NFA will not make either proposal effective until both are approved by the Commission.

NFA respectfully requests that the Commission review and approve the proposed amendments and requests that they be declared effective upon Commission approval.

Proposed Deletion of NFA Compliance Rule 2-8(e)(2)

Proposed Amendment to NFA Compliance Rule 2-29(b)(5)

Explanation of Proposed Amendments

Respectfully submitted,

Daniel J. Roth
General Counsel

cc: Chairperson 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.


*By letter dated April 23, 1998, the Commission notified NFA that it has approved the deletion of Compliance Rule 2-8(e)(2) as proposed.

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