NFA questioned the "proposed methodology" of a CFTC proposal that would apply to direct clearing of transactions by customers not intermediated through an FCM.
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The NFA submitted to the CFTC proposed changes to bylaws related to the qualifications for public directors on the NFA's Board.
The Board of Governors of the Federal Reserve adopted new operational risk management requirements for systemically important designated clearing organizations.
The NFA submitted to the CFTC proposed changes to compliance rules, bylaws and interpretive guidance related to Member Questionnaires requirements.
NFA questioned the rationale and benefits of proposed changes in a CFTC proposal to increase the disclosure requirements for commodity pools and managed account programs operated by registered commodity pool operators and commodity trading advisors.