Shipkevich Bitcoin and ICO Attorney
Felix Shipkevich October 20, 2009

The proposed amendments would broaden the language in the Commission’s regulations applicable to electronic filings of financial reports to clarify that, to the extent a futures commission merchant (‘‘FCM’’) submits a Form 1–FR to the Commission electronically, it may do so using any user authentication procedures established or approved by the Commission.

The changes would:
• enable internet-based filing of FCM financial reports using user authentication and password procedures in anticipation of expected changes to the WinJammer™ software application;
• expand the types of filings that FCMs and IBs may submit electronically to include required “early warning” notices and certain other notices and filings;
• provide for less prescriptive, but more immediate, documentation to be filed regarding a firm’s undercapitalized condition; and
• expressly require that an income statement be included in the periodic unaudited financial reports of FCMs and IBs.