Pursuant to Section 17(j) of the Commodity Exchange Act, as amended, the NFA hereby submitted to the CFTC proposed amendments to Financial Requirements Section 1 regarding minimum net capital requirements for futures commission merchants and introducing brokers. NFA’s Board of Directors approved this proposal on February 18, 2010.

• Increase the minimum dollar capital requirement from $500,000 to $1,000,000;

• Increase the risk-based capital requirement for non-customer accounts from 4% to 8% of the total risk margin requirement for positions carried in non-customer accounts; and

• Include cleared over-the counter derivative positions in an FCM’s risk based capital calculation for customer and non-customer accounts.