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Commentary by Steven Lofchie

The National Futures Association ("NFA") proposed amendments to NFA Compliance Rules and Interpretive Notices to cover transactions and counterparties involving swaps. The NFA stated that the amendments to the NFA Rules are designed to (i) incorporate references to swaps and counterparties, as well as other related concepts, (ii) clarify that certain rules apply to all commodity interests, defined as means futures, forex and/or swaps, and (iii) clarify that other rules only apply to certain membership categories. Specifically, the NFA proposed amending: NFA Compliance Rule 1-1 ("Definitions")