Comment Letters
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| 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 RequirementThe 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 RequirementsThe 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 PersonsThe 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 PracticesFIA 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 ActComment 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 QuebecFIA 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 StatesFIA 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 FuturesProposed 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 ActJoint 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-RegulationResponding 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 LegislationAssociations 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 RulesFIA 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 BusinessFiled May 25, 2005
» FIA Comment Letter |
Consultation Paper on The Proposal for the Removal of Barrier 1 of the Giovannini ReportSWIFT s.c.
Filed April 14, 2005
» FIA Comment Letter |
Proposed Withdrawal of Staff Interpretation70 Fed. Reg. 5417 (February 2, 2005)
Filed April 5, 2005
» FIA Comment Letter |
CBOE/NYSE Customer Portfolio and Cross Margining RequirementsCBOE 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 Statement69 Fed.Reg. 64873 (November 9, 2004)
Filed December 7, 2004
» FIA Comment letter |
The Governance of Self Regulatory Organizations69 Fed.Reg. 32326
Filed September 30, 2004
» FIA Comment Letter |
Execution of Transactions: Rule 1.38 and Guidance on Core Principle 969 Fed.Reg. 39880
Filed August 27, 2004
» FIA Comment Letter |
Futures Commission Merchant and Introducing Broker Customer Identification Rule—Request for No-Action PositionFiled May 5, 2004
» FIA Comment Letter |
NASD Notice to Members 04-07: Policy on Trail Commissions in Publicly Offered Commodity Pools
» FIA Comment Letter |
Joint Industry Letter Opposing Feinstein AmendmentFiled November 4, 2003
» FIA Comment Letter |
Proposed Amendments to Rule 1.25—Investment of Customer Funds68 Fed.Reg. 38654 (June 30, 2003)
» FIA Comment Letter |
Minimum Financial and Related Reporting Requirements for Futures Commission Merchants and Introducing Brokers68 Fed.Reg. 40835 (July 9, 2003)
» FIA Comment Letter |
NPRM—Suspicious Transaction Reporting—Futures Commission Merchants and Introducing Brokers in Commodities68 Fed. Reg. 23,653 (May 5, 2003)
» FIA Comment Letter |
Advanced Notice of Proposed Rulemaking on CPO and CTA Registration Exemptions
» FIA Comment Letter |
Proposed Rules Relating to Credit by Brokers and Dealers; Security Futures67 Fed. Reg. 62,214 (October 4, 2002); Docket No. R?1131
» FIA Comment Letter |
Reserve Requirements for Margin Related to Security Futures Products67 Fed.Reg. 59748 (September 23, 2002), File No. S7-34-02
» FIA Comment Letter |
Proposed Rule 1.49—Foreign Depositories67 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. SenateAgainst 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 |
Section 326 Proposed Rule—Customer Identification67 Fed.Reg. 48238, July 23, 2002
» FIA Comment Letter |
| Interim Relief Related to the Trading of Foreign Security Futures ProductsJuly 3, 2002 |
Notice of proposed rulemaking on anti-money laundering due diligence programs for certain foreign accountsJuly 1, 2002
» FIA Comment Letter |
FIA/SIA Joint Comment LetterNational 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 Systems67 Fed.Reg. 14701 (March 27, 2002)
April 26, 2002
» FIA Comment Letter |
Study of the Commodity Exchange Act and Rules Thereunder66 Fed. Reg. 33531 (June 22, 2001)
April 5, 2002
» FIA Comment Letter |
Special Information Sharing Procedures to Deter Money Laundering and Terrorist ActivitiesAttention: Proposed Rule -- Special Information Sharing Section 314
April 3, 2002
» FIA Comment Letter |
NPRM – Suspicious Transaction Reporting – Brokers or Dealers in SecuritiesMarch 1, 2002
» FIA Comment Letter |
Interim Report: Recommendations for Standardization of Protocol and Content of Order FlowFebruary 20, 2002
» Comment Letter |
Treatment of Customer Funds66 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 Futures66 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 SystemsAugust 31, 2001
» FIA Comment Letter |
Registration of Broker Dealers Pursuant to Section 15(b)(11) of the Exchange Act, 66 Fed.Reg. 34041July 26, 2001
» FIA Comment Letter |
Narrow-Based Security Indexes, 66 Fed. Reg. 27560 (May 17, 2001)July 18, 2001
» FIA Comment Letter |
CME Proposed New Rule 526 to Establish Block Trading ProceduresApril 24, 2000
» FIA Comment Letter |
Recommendations for Legislative and Regulatory Reform Under the Commodity Exchange ActMarch 27, 2000
» FIA Comment Letter |
CFTC Proposed Amendment to Rule 1.41, 64 Fed.Reg. 66428February 24, 2000
» FIA Comment Letter |
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