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The Institute for Financial Markets
 
Comment Letters

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FIA “Strongly Supports” Proposed CFTC Exemption for Foreign Brokers
Washington—Feb. 27, 2008—The FIA has filed a comment letter with the Commodity Futures Trading Commission saying it “strongly supports” a proposed exemption from the CFTC’s registration requirements for foreign brokers that are affiliated with U.S. futures commission merchants. The proposed exemption, which was requested by the FIA Law & Compliance Division, “has become increasingly important to FCMs and their affiliates as their institutional customers extend their trading activities to a growing number of international markets,” the FIA letter said. As explained in the letter, the proposed exemption would codify several no-action letters adopted by the CFTC’s Division of Clearing and Intermediary Oversight, “pursuant to which foreign affiliates of certain U.S. FCMs have been authorized to accept orders from U.S. institutional customers for execution on U.S. designated contract markets notwithstanding that such affiliates are not registered with the commission as introducing brokers.” The exemption would be limited to foreign firms that are affiliated with a registered FCM and that already have obtained exemptive relief from the CFTC pursuant to Regulation 30.10. In addition, the foreign firm would not be permitted to solicit any U.S. customers for trading on U.S. markets nor handle any U.S. customer funds for trading on U.S. markets.
FIA Urges Treasury to Endorse Principles-Based Regulation, Says Merger of CFTC with SEC Should Be Last Step

The Futures Industry Association submitted a comment letter to the Treasury Department on Nov. 20, 2007 outlining its views on the structure of financial services regulation in the U.S.

FIA Files Comment Letter with U.K.’s FSA Regarding Proposed Telephone Recording Requirement
The FIA filed a comment letter with the Financial Services Authority on Aug. 3 expressing opposition to a proposed requirement that all telephone conversations be recorded.
Comments on Proposed National Instrument 31-103 - Registration Requirements
The Futures Industry Association (“FIA”) is pleased to provide this comment letter to the Canadian Securities Administrators (“CSA”) with respect to Proposed National Instrument 31-103 – Registration Requirements (“NI 31-103”).

View Comment letter

“What Constitutes a Board of Trade Located Outside of the United States,” 71 Fed. Reg. 34070 (June 13, 2006)

The Commodity Futures Trading Commission has requested public comment on when a board of trade should be considered to be "located outside the Unites States" for purposes of Section 4(a) of the Commodity Exchange Act. 71 Fed. Reg. 34070 (June 13, 2006).

View Comment letter

Exemption From Registration for Certain Foreign Persons
The Commodity Futures Trading Commission recently proposed amendments to its futures commission merchant registration rules to exempt from U.S. registration brokers outside the U.S. that are engaged in the offer and sale of futures and options traded on U.S. exchanges solely to non-U.S. customers.

"Regulatory Governance," Proposed Acceptable Practices
FIA response to CFTC request for public comment on its "Proposed Acceptable Practices for compliance with section 5(d)(15) of the Commodity Exchange Act".
August 28, 2006
» FIA Comment Letter
Review of Ontario's Commodity Futures Act
Comment Letter to the Ontario Commodity Futures Act Advisory Committee with respect to the Committee's Interim Report.
August 25, 2006
» FIA Comment Letter
Regulation of Derivatives Markets in Quebec
FIA response to the AMF report entitled "Regulation of Derivatives Markets in Quebec"
August 25, 2006
» FIA Comment Letter
What Constitutes a Board of Trade Located Outside of the United States
FIA responds to CFTC request for comments on when a board of trade should be considered to be "located outside the United States".
August 1, 2006
» FIA Comment Letter
FIA Seeks Clarification of Proposed Rules for Debt Index Futures
Proposed Rules: Application of the Definition of Narrow-Based Security Index to Debt Securities Indexes and Security Futures on Debt Securities
May 16, 2006
» FIA Comment Letter
FIA Comment Letter on Section 312 of USA PATRIOT Act
Joint Comment Letter on the Notice of Proposed Rulemaking issued by the Department of the Treasury and the Financial Crimes Enforcement Network relating to a proposed regulation to implement the provisions of Section 312 of the USA PATRIOT Act that require enhanced due diligence for correspondent accounts established, maintained, administered or managed for certain types of foreign banks.
March 6, 2006
» Joint Comment Letter
FIA Outlines Views on Self-Regulation
Responding to a request from the Commodity Futures Trading Commission, the FIA on Jan. 23 filed a comment letter outlining its views on a number of issues related to the futures industry's self-regulatory system, including the governance of self-regulatory organization, the composition of disciplinary committees, and the need for transparency in exchange rule-making.
January 25, 2006
» FIA Comment Letter
Opposition to Proposed CFTC Reauthorization Legislation
Associations urge postponement of December 7 markup to allow further revisions to House Agriculture Committee draft bill.
December 7, 2005
» Joint Comment Letter
FIA Comments on CSE Rules
FIA comments on amendments proposed in CFTC Federal Register from October 11, 2005: Alternative Market Risk and Credit Risk Capital Charges for Futures Commission Merchants and Specified Foreign Currency and Inventory Charges.
November 28, 2005
» FIA Comment Letter
CESR-CFTC Communiqué Requests Comments on Common Work Program to Facilitate Trans-Atlantic Derivatives Business
Filed May 25, 2005
» FIA Comment Letter
Consultation Paper on The Proposal for the Removal of Barrier 1 of the Giovannini Report
SWIFT s.c.
Filed April 14, 2005
» FIA Comment Letter
Proposed Withdrawal of Staff Interpretation
70 Fed. Reg. 5417 (February 2, 2005)
Filed April 5, 2005
» FIA Comment Letter
CBOE/NYSE Customer Portfolio and Cross Margining Requirements
CBOE Customer Portfolio and Cross Margining Requirements File Number SR-CBOE-2002-03, 69 Fed.Reg. 77275
NYSE Customer Portfolio and Cross Margining Requirements File Number SR-NYSE-2002-19, 69 Fed.Reg. 77287
Filed March 4, 2005
» FIA Comment Letter
Proposed Amendments to Commission Rule 1.55(d)(1)—Distribution of Risk Disclosure Statement
69 Fed.Reg. 64873 (November 9, 2004)
Filed December 7, 2004
» FIA Comment letter
The Governance of Self Regulatory Organizations
69 Fed.Reg. 32326
Filed September 30, 2004
» FIA Comment Letter
Execution of Transactions: Rule 1.38 and Guidance on Core Principle 9
69 Fed.Reg. 39880
Filed August 27, 2004
» FIA Comment Letter
Futures Market Self-Regulation
69 Fed.Reg. 19166
Filed June 18, 2004
» FIA Comment Letter
Futures Commission Merchant and Introducing Broker Customer Identification Rule—Request for No-Action Position
Filed May 5, 2004
» FIA Comment Letter
NASD Notice to Members 04-07: Policy on Trail Commissions in Publicly Offered Commodity Pools

» FIA Comment Letter
Designation of U.S. Futures Exchange L.L.C. as a Contract Market

» FIA Comment Letter
Joint Trade Association Letter regarding the Eurex US Application

» FIA Comment Letter
Joint Industry Letter Opposing Feinstein Amendment
Filed November 4, 2003
» FIA Comment Letter
US Futures Exchange LLC

» FIA Comment Letter
Proposed Amendments to Rule 1.25—Investment of Customer Funds
68 Fed.Reg. 38654 (June 30, 2003)
» FIA Comment Letter
Minimum Financial and Related Reporting Requirements for Futures Commission Merchants and Introducing Brokers
68 Fed.Reg. 40835 (July 9, 2003)
» FIA Comment Letter
Customer Identification Programs for FCMs and IBs

» FIA Comment Letter
FIA Comment Letter on CBOT and CME Rules

» FIA Comment Letter
NPRM—Suspicious Transaction Reporting—Futures Commission Merchants and Introducing Brokers in Commodities
68 Fed. Reg. 23,653 (May 5, 2003)
» FIA Comment Letter
FIA Comments on CBOT/CME Link

» FIA Comment Letter
Proposed Amendments to Rule 1.35(a-1)(5)—Post-Execution Allocation of Bunched Orders
68 Fed.Reg. 12319 (March 14, 2003)
» FIA Comment Letter
» CFTC Proposed Rule Revisions
Advanced Notice of Proposed Rulemaking on CPO and CTA Registration Exemptions

» FIA Comment Letter
Proposed Rules Relating to Credit by Brokers and Dealers; Security Futures
67 Fed. Reg. 62,214 (October 4, 2002); Docket No. R?1131
» FIA Comment Letter
Reserve Requirements for Margin Related to Security Futures Products
67 Fed.Reg. 59748 (September 23, 2002), File No. S7-34-02
» FIA Comment Letter
Proposed Rule 1.49—Foreign Depositories
67 Fed.Reg. 52641 (August 13, 2002)
» FIA Comment Letter
Proposed Suspicious Activity Report by the Securities and Futures Industry (SAR-SF)
October 4, 2002
» FIA Comment Letter
Joint Association Letter to U.S. Senate
Against adoption of proposed energy derivativeslegislation as a part of final legislative initiatives opposing any attempt to approve controversial, detrimental and anti-competitive derivativeslegislation.
» Joint Comment Letter
NASD Gross Income Assessments, 67 Fed.Reg. 55893
August 30, 2002
» CFTC Comment Letter
Section 326 Proposed Rule—Customer Identification
67 Fed.Reg. 48238, July 23, 2002
» FIA Comment Letter
FIA/SIA Review of the FATF Forty Recommendations Consultation Paper
August 30, 2002
» FIA/SIA Comment Letter
Release No. 34-46186; File No. SR-NASD-2002-40
August 9, 2002
» FIA Comment Letter
Interim Relief Related to the Trading of Foreign Security Futures Products
July 3, 2002
Notice of proposed rulemaking on anti-money laundering due diligence programs for certain foreign accounts
July 1, 2002
» FIA Comment Letter
FIA/SIA Joint Comment Letter
National Futures Association Proposed Interpretive Notice to NFA Compliance Rule 2-4 Regarding Broker-Dealer Best Execution Obligations with Respect to Security Futures
Release No. 34-45720; SEC File No. SR-NFA-2002-02
» Joint Comment Letter
NFA Interpretive Notice Regarding Supervision of Automated Order Routing Systems
67 Fed.Reg. 14701 (March 27, 2002)
April 26, 2002
» FIA Comment Letter
Senator Feinstein’s amendment to S.517
April 8, 2002
» FIA Comment Letter
Study of the Commodity Exchange Act and Rules Thereunder
66 Fed. Reg. 33531 (June 22, 2001)
April 5, 2002
» FIA Comment Letter
Special Information Sharing Procedures to Deter Money Laundering and Terrorist Activities
Attention: Proposed Rule -- Special Information Sharing Section 314
April 3, 2002
» FIA Comment Letter
NPRM – Suspicious Transaction Reporting – Brokers or Dealers in Securities
March 1, 2002
» FIA Comment Letter
Interim Report: Recommendations for Standardization of Protocol and Content of Order Flow
February 20, 2002
» Comment Letter
Treatment of Customer Funds
66 Fed. Reg. 50786 (October 4, 2001)
CFTC: Proposed Rule 41.42 – Treatment of Customer Funds
SEC File No. S7-17-01
» FIA Comment Letter
Proposed Customer Margin Rules Relating to Security Futures
66 Fed. Reg. 50720 (October 4, 2001); Release No. 34-44853
SEC File No. S7-16-01
» FIA Comment Letter
» Appendix
Interpretative Notice Regarding Automated Order Routing Systems
August 31, 2001
» FIA Comment Letter
Registration of Broker Dealers Pursuant to Section 15(b)(11) of the Exchange Act, 66 Fed.Reg. 34041
July 26, 2001
» FIA Comment Letter
Narrow-Based Security Indexes, 66 Fed. Reg. 27560 (May 17, 2001)
July 18, 2001
» FIA Comment Letter
Proposed Rule 1.68. 66 (Fed. Reg. 14506)
April 9, 2001
» FIA Comment Letter
Proposed Privacy Regulations (66 Fed. Reg. 15549)
March 19, 2001
» FIA Comment Letter
» Federal Register
Proposed Regulatory Framework for Trading Facilities (66 Fed Reg 14262)
March 9, 2001
» FIA Comment Letter
» Federal Register
A New Regulatory Framework
August 16, 2000
» FIA Comment Letter
S. 2697—Commodity Futures Modernization Act of 2000
June 23, 2000
» FIA Comment Letter
HR4541 Commodity Futures Modernization Act of 2000
June 21, 2000
» FIA Comment Letter
» Exhibits
CME Proposed New Rule 526 to Establish Block Trading Procedures
April 24, 2000
» FIA Comment Letter
Recommendations for Legislative and Regulatory Reform Under the Commodity Exchange Act
March 27, 2000
» FIA Comment Letter
CFTC Proposed Amendment to Rule 1.41, 64 Fed.Reg. 66428
February 24, 2000
» FIA Comment Letter
CFFE Block Trading Rules
February 14, 2000
» FIA Comment Letter
UK Financial Promotion under the Financial Services and Markets Bill
February 8, 2000
» FIA Comment Letter
» Financial Promotion - Second Consultation Document
Exemption From Registration as a Commodity Trading Advisor
February 7, 2000
» FIA Comment Letter

March 7, 2000
» CFTC Final Rule

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