Shipkevich Bitcoin and ICO Attorney
Felix Shipkevich February 22, 2010

Pursuant to Section 17(j) of the Commodity Exchange Act, as amended, NFA hereby submits to the CFTC proposed amendments to Financial Requirements Sections 11(b) and (c) regarding Forex Dealer Member financial requirements and the Interpretive Notice regarding Forex Transactions. NFA’s Board of Directors approved this proposal on February 18, 2010.

Financial Requirements Section 11(b) and (c) prohibit Forex Dealer Members (FDMs) from including assets held at unregulated persons as current assets for purposes of determining adjusted net capital and from using such unregulated persons to cover currency positions. The rule defines a person as unregulated unless it is one of the persons enumerated in the rule. The enumerated persons include, among others, futures commission merchants registered with the CFTC and brokerdealers registered with the SEC, as well as certain entities regulated as a foreign equivalent.

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