Shipkevich Bitcoin and ICO Attorney
Felix Shipkevich December 3, 2009

NFA Bylaw 1301(e) requires Forex Dealer Members to pay annual dues that are
graduated according to the firm’s gross annual revenue from customers (e.g.,
commissions, mark-ups, mark-downs) for its forex activities. Profits and losses
from proprietary trades are not to be included. To calculate dues:
• Start with the FCM dues imposed by NFA Bylaw 1301(b)(ii);
• Add $44,375 if the Forex Dealer Member’s gross annual revenue from
forex transactions is $500,000 or less;
• Add $69,375 if the Forex Dealer Member’s gross annual revenue from
forex transactions is more than $500,000, but not more than $2,000,000;
• Add $94,375 if the Forex Dealer Member’s gross annual revenue from
forex transactions is more than $2,000,000, but not more than $5,000,000;
or
• Add $119,375 if the Forex Dealer Member’s gross annual revenue from
these activities is more than $5,000,000.

These dues apply when the Forex Dealer Member offers to be a counterparty to
a forex transaction or accepts a forex trade (whichever is earlier), and NFA will
send the Member an invoice for the minimum dues ($50,000 or $45,875) minus
any amount already paid for that membership year. Thereafter, the dues will be
assessed on the firm’s membership renewal date and will be based on the Forex
Dealer Member’s latest certified financial statement.

(proposed amendment)
The only exception to the dues set forth above is a situation in which NFA does
not serve as the DSRO for a Forex Dealer Member and the DSRO has agreed to
examine the Forex Dealer Member’s forex activities. In this case, the surcharge
paid by the Forex Dealer Member, regardless of gross annual revenue, is
$12,000. Accordingly, for such a Forex Dealer Member the dues to be assessed
at the time it offers to be a counterparty to a forex transaction or accepts a forex
trade (whichever is earlier), and on its membership renewal date thereafter, will
be $13,500.

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