Rule Submissions to the CFTC

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March 1, 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 NFA Financial Requirements*

Dear Ms. Webb:

National Futures Association ("NFA") hereby submits to the Commodity Futures Trading Commission ("CFTC" or "Commission") proposed technical amendments to NFA Financial Requirements. The amendments contained herein were approved by NFA's Board of Directors ("Board") on February 18, 1999.

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.

Explanation of Proposals

Financial Requirements

Schedule A Financial Requirements Computation

Schedule B Equity Capital

Schedule C Subordinated Loan Agreements

Schedule D Financial Reports

Schedule E Procedures for Relief Requests

Respectfully submitted,

Daniel J. Roth
General Counsel

cc: Chairman Brooksley Born
Commissioner Barbara Pedersen Holum
Commissioner David D. Spears
Commissioner James E. Newsome
Geoffrey Aronow, Esq.
I. Michael Greenberger, Esq.
Alan L. Seifert, Esq.
Lawrence B. Patent, Esq.
David Van Wagner, Esq.

* The proposed amendments to NFA Financial Requirements became effective on December 17, 1999.

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