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April 22, 2002
Ms. Jean A. Webb
Commodity Futures Trading Commission
Three Lafayette Centre
1155 21st Street, N.W.
Washington, DC 20581
Re: National Futures Association: Proposed Amendments to NFA Compliance Rule 2-9 and Proposed Adoption of an Interpretive Notice Regarding FCM and IB Anti-Money Laundering Program.*
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 2-9 and the proposed adoption of an Interpretive Notice Regarding FCM and IB Anti-Money Laundering Program. The amendments to Rule 2-9 and the proposed Notice were approved by NFA's Board of Directors ("Board") on February 21, 2002. At that meeting, the Board authorized NFA's Executive Committee to make additional changes that may be requested by the Department of the Treasury ("Treasury"), the CFTC, the Futures Industry Association ("FIA"), the National Introducing Brokers Association ("NIBA") or the Managed Funds Association ("MFA"). The final versions of the amendments to Rule 2-9 and the Notice, as reflected in this submission, were approved by the Executive Committee on April 18, 2002. NFA respectfully requests Commission review and approval of the proposals contained herein.
NFA respectfully requests that the Commission review and approve the proposal contained herein. By law, financial institutions must be in compliance with the requirements of Section 352 on or before April 24, 2002, and, therefore, we are seeking the Commission's approval by that date.
Thomas W. Sexton
Vice President and General Counsel
cc: Chairman James E. Newsome
Commissioner Barbara Pedersen Holum
Commissioner Thomas J. Erickson
John C. Lawton, Esq.
Gregory Mocek, Esq.
Patrick J. McCarty, Esq.
David Van Wagner, Esq.
Riva Spear Adriance, Esq.
*The proposed amendments to NFA Compliance Rule 2-9 and the proposed adoption of Interpretive Notice Regarding FCM And IB Anti-Money Laundering Program became effective on April 23, 2002.