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June 02, 1999
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 Sections 7, 11 and 18 of NFA's Code of Arbitration, Sections 6 and 11 of NFA's Member Arbitration Rules, and NFA Financial 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 Sections 7, 11 and 18 of NFA's Code of Arbitration and Sections 6 and 11 of NFA's Member Arbitration Rules. By letter dated March 1, 1999, NFA submitted to the Commission for its review and approval proposed amendments to NFA Financial Requirements. NFA hereby withdraws that submission and resubmits the proposal as set forth herein. The proposed amendments contained in this submission were approved by NFA's Board of Directors ("Board") on May 20, 1999.
NFA respectfully requests that the Commission review and approve the proposed amendments and that they be declared effective upon Commission approval.
Daniel J. Roth
cc: Commissioner Barbara Pedersen Holum
Commissioner David D. Spears
Commissioner James E. Newsome
I. Michael Greenberger, Esq.
Alan L. Seifert, Esq.
Lawrence B. Patent, Esq.
David Van Wagner, Esq.
Riva Spear Adriance, Esq.
* The proposed amendments to the Code of Arbitration Section 7(a) and 18, and the Member Arbitration Rules Section 6(a) became effective on December 17, 1999. The proposed amendments to the Code of Arbitration Section 11(a) and the Member Arbitration Rules Section 11(a) became effective on February 1, 2000.