Commodity Futures Trading Commission.
The Commodity Futures Trading Commission (“Commission” or “CFTC”) is adopting a new rule (“Final Rule”) to require that all persons registered with the Commission as introducing brokers (“IB”), commodity pool operators (“CPO”), or commodity trading advisors (“CTA”), subject to an exception for those persons who are exempt from registration as a CTA pursuant to a particular provision of the Commission's regulations, must, in each case, become and remain a member of at least one registered futures association (“RFA”).
The Final Rule will become effective November 13, 2015. All persons subject to the Final Rule must comply with the Final Rule by not later than December 31, 2015.
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Katherine Driscoll, Associate Chief Start Printed Page 55023Counsel, 202-418-5544, email@example.com; or Jacob Chachkin, Special Counsel, 202-418-5496, firstname.lastname@example.org, Division of Swap Dealer and Intermediary Oversight, Commodity Futures Trading Commission, Three Lafayette Centre, 1155 21st Street NW., Washington, DC 20581.
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Part 170 of the Commission's regulations relates to RFAs. An RFA is an association of persons registered with the Commission as such pursuant to Section 17 of the Commodity Exchange Act (“CEA” or “Act”).
Subject to Commission oversight, RFAs serve a vital self-regulatory role by functioning as frontline regulators of their members (which members also remain subject to Commission oversight).
An RFA cannot enforce its rules over Commission registrants who are not members of the RFA.
As such, the Commission promulgated regulations 170.15 and 170.16 to require each registered futures commission merchant (“FCM”), and each registered swap dealer (“SD”) and major swap participant (“MSP”), respectively, to be an RFA member, subject to an exception for certain notice registered securities brokers or dealers.
Because the National Futures Association (“NFA”) was the only RFA under Section 17(a) of the CEA  at the time § 170.15 and § 170.16, respectively, were promulgated, these registered FCMs, SDs, and MSPs were required to be NFA members and, thus, were subject to NFA's rules. The Commission did not promulgate regulations requiring other Commission registrants, including IBs,
CPOs, and CTAs, to be members of an RFA. One of the NFA rules to which NFA members are subject, however, is NFA's Bylaw 1101. NFA Bylaw 1101 requires that, generally, no NFA member may “carry an account, accept an order or handle a transaction in commodity futures contracts” for, or on behalf of, any non-member of NFA that is required to be registered with the Commission as, among other things, an IB, CPO, or CTA.
Accordingly, any IB, CPO, or CTA required to be registered with the Commission that desires to conduct business with respect to commodity futures contracts directly with an FCM that is an NFA member must also become an NFA member, and derivatively, must ensure that it only conducts such business with those IBs, CPOs, or CTAs that also are NFA members. Therefore, § 170.15, at the time it was promulgated, operated in conjunction with NFA Bylaw 1101 “to assure essentially complete NFA membership from the universe of commodity professionals: [FCMs, CPOs, CTAs, and IBs].” 
Title VII of the Dodd-Frank Wall Street Reform and Consumer Protection Act (“Dodd-Frank Act”) amended the Start Printed Page 55024CEA to establish a comprehensive new regulatory framework for swaps and security-based swaps.
The new regulatory framework provides that, among other things, persons that engage in regulated activity with respect to swaps will be required to register with the Commission as IBs, CPOs, or CTAs, as appropriate. Because of these definitional amendments, the intersection of § 170.15 and NFA Bylaw 1101 no longer assures NFA membership for IBs, CPOs, or CTAs that are required to register with the Commission because, as noted above, NFA Bylaw 1101 relates only to commodity futures contracts.
II. Proposed Rule
On November 8, 2013, the Commission proposed to amend part 170 by adding § 170.17, which would, if adopted, have required each IB, CPO, and CTA registered with the Commission to become and remain a member of at least one RFA (“Proposal”).
In the Proposal, the Commission specifically solicited comments regarding, among other things, the impact of the Proposal on CTAs that are registered with the Commission despite being eligible to rely on the exemption from registration set forth in Commission regulation 4.14(a)(9) (“§ 4.14(a)(9) Exempted CTAs”).
Regulation 4.14(a)(9) provides that a person is not required to register with the Commission as a CTA if it does not: (i) Direct any client accounts; or (ii) provide commodity trading advice based on, or tailored to, the commodity interest or cash market positions or other circumstances or characteristics of particular clients.
When the Commission promulgated regulation 4.14(a)(9), it stated that “[a] CTA exempt under rule 4.14(a)(9) that wishes to apply for registration or retain its current registration may do so.” 
Therefore, CTAs that may avail themselves of the exemption from registration in regulation 4.14(a)(9) may be currently registered with the Commission and may so register in the future.
The comment period for the Proposal ended on January 7, 2014.
The Commission received two substantive comments in response to the Proposal 
and, in consideration of those comments, is adopting the Proposal subject to certain changes, as noted below.
III. Summary of Comments
In response to the Proposal, the Commission received two substantive comments, one from NFA and one from James W. Lovely, Esq. (“Lovely”).
Both comments related to the impact of the Proposal on CTAs. No comments were received in response to the CPO and IB aspects of the Proposal.
A. NFA Comment
NFA supported the Proposal as an appropriate and effective way to require IBs, CPOs, and CTAs engaging in swaps activities that otherwise are not captured by the intersection of NFA Bylaw 1101 or NFA Compliance Rule 2-36 
to become and remain NFA members, and comply with the applicable NFA requirements. However, NFA recommended that the Commission exclude § 4.14(a)(9) Exempted CTAs from the Proposal. In support of its position, NFA stated that its existing rules focus primarily on an intermediary's conduct with respect to clients and thus have little applicability to CTAs that do not direct client accounts or otherwise exercise discretion (i.e., § 4.14(a)(9) Exempted CTAs).
B. Lovely Comment
Conversely, Lovely generally stated that the Proposal “while well-intentioned, is ill-founded in many respects” and argued that the costs associated with further requiring registered CTAs to become and remain RFA members would be disproportionate to any regulatory benefit.
Lovely discussed those CTAs that register with the Commission even though they may not be required to so register (e.g., because they may avail themselves of a registration exception or exclusion provided under Commission regulation 4.14(a) or Sections 1a(12)(B) or 4m(1) of the CEA, respectively). According to Lovely, these CTAs register for legal comfort in light of the “practical ambiguities around concepts [related to CTA registration requirements] such as `solely incidental', `principal business or profession', `holding out' and `tailored advice'” but do not have to become NFA members, so long as such CTAs do not manage or exercise discretion over customer accounts or funds.
He argues that these CTAs' voluntary registration benefits the CFTC and that such persons will likely deregister if the Commission adopts the Proposal.
Lovely further stated that the CFTC “significantly underestimates the cost of NFA [membership]” for these CTAs who are not currently required to become NFA members. He noted that most of such CTAs “have only incidental involvement with commodity interests” and, if required to become NFA members, “would need to retain external legal counsel or compliance consultants to try to ascertain [which NFA rules] apply to their activities and, if so, how to comply with the same.” Notwithstanding that Lovely argues that many NFA rules are not applicable to such CTAs,
he estimates that “external Start Printed Page 55025legal and compliance assistance . . . could easily cost [such a CTA] $15,000.00 to $20,000.00 per year.”
IV. Final Rule
The Commission, in consideration of the comments received by it on the Proposal, is adopting the Proposal but excluding § 4.14(a)(9) Exempted CTAs from the Final Rule.
The Final Rule will help ensure the integrity of the swaps and futures market and its participants by subjecting all registered IBs, CPOs, and CTAs, except for § 4.14(a)(9) Exempted CTAs, to NFA's developed set of rules and oversight capabilities.
As such, the Commission believes that the markets are better served, and the public better protected, by having persons subject to the requirements of the Final Rule become RFA members.
After considering the comments, the Commission is persuaded by Lovely and NFA that NFA's rules have little applicability to § 4.14(a)(9) Exempted CTAs and, thus, there would be little benefit from requiring § 4.14(a)(9) Exempted CTAs to become and remain RFA members.
The Commission, however, is not persuaded that other registered CTAs, regardless of whether such CTAs are required to register with the Commission, should be excluded from the requirements of the Final Rule. Any registered CTA that does not meet the requirements of § 4.14(a)(9) would, by definition, be engaged in either (i) directing client accounts, or (ii) providing commodity trading advice based on, or tailored to, the commodity interest or cash market positions or other circumstances or characteristics of particular clients. As noted above, and consistent with § 170.15, the Commission believes that RFA supervision of registered CTAs engaging in these activities is beneficial to the markets and the clients of such CTAs.
In addition, the Commission believes that Lovely's cost estimates are very high for retaining advisors in relation to NFA's rules. Assuming a CTA was to contact an attorney familiar with Commission regulations and NFA rules applicable to CTAs, the Commission believes that determining which NFA rules are applicable to such a CTA would be a routine task that would not take a substantial amount of time.
Furthermore, with respect to those CTAs that opt into CFTC registration to avoid making determinations as to their activities in relation to their eligibility for the exceptions or exclusions from the CTA registration requirements noted in Lovely's comments, such persons should review available guidance from the Commission and consult with their advisors and Commission staff, as necessary, to determine if registration is required.
In support of the Final Rule, Section 4p of the CEA authorizes the Commission to “specify by rules and regulations appropriate standards with respect to training, experience, and such other qualifications as the Commission finds necessary or desirable to insure the fitness of persons required to be registered with the Commission.” 
The Final Rule also provides a means for assuring that the purpose of Section 17(m) of the CEA,
allowing for compulsory RFA membership, is achieved.
The Commission believes that the Final Rule is reasonably necessary and desirable to effectuate comprehensive and effective market oversight by NFA in its capacity as an SRO. As the only RFA, NFA serves as the frontline regulator of its members, subject to Commission oversight. Without such mandatory membership in NFA or another RFA, effective implementation of the programs required by Section 17 of the CEA and NFA's self-regulatory programs could be impeded.
In summary, by mandating RFA membership by each registered IB, CPO, and CTA, except § 4.14(a)(9) Exempted CTAs, the Final Rule enables the Commission to further ensure the fitness, and provide for direct NFA oversight, of these Commission registrants.
V. Administrative Compliance
A. Paperwork Reduction Act
The Paperwork Reduction Act of 1995 (“PRA”) 
imposes certain requirements on Federal agencies, including the Commission, in connection with their conducting or sponsoring any collection of information, as defined by the PRA. An agency may not conduct or sponsor, and a registered entity is not required to respond to, a collection of information unless it displays a currently valid control number by the Office of Management and Budget (“OMB”).
In connection with the Proposal, the Commission anticipated that, if adopted, the Final Rule would simply require an amendment to the number of respondents included in OMB Collection 3038-0023.
The basis for this preliminary finding was that, at the time of the Proposal, NFA had indicated that certain CPOs, CTAs, and IBs were registered with the Commission, but not NFA members. Therefore, because registration and membership require the filing of Form 7-R, the Commission initially believed these respondents' paperwork burden would have been affected by the Proposal.
As discussed above, the Final Rule does not require IBs, CPOs, or CTAs to Start Printed Page 55026
register with the Commission. Rather, the Final Rule only requires that certain of such persons that register with the Commission become and remain an NFA member. To indicate NFA membership an applicant needs to “check a box” on Form 7-R.
Current OMB Collection 3038-0023 captures the burdens associated with the registration process for these persons, including the filing of and updating of Form 7-R for registration purposes. Therefore, to comply with the Final Rule, such registrants that are not NFA members, would be required to “check-the-box” on Form 7-R indicating their status as an NFA member.
Accordingly, because the burden associated with updating Form 7-R is currently captured in OMB Collection 3038-0023, and those persons who are directly impacted by the Final Rule are either currently registered with the Commission (i.e., have already filed a Form 7-R) or will be required to file a Form 7-R in connection with their registration with the Commission, no adjustment is necessary to take into account the number of Commission registrants who will have to become NFA members as a result of the Final Rule. Further, the Commission believes the additional burden of “checking the box” on Form 7-R to be non-substantive. Therefore, upon further review and for the reasons stated above, the Final Rule does not require amending existing OMB Collection 3038-0023.
B. Regulatory Flexibility Act
The Regulatory Flexibility Act 
requires federal agencies, in promulgating regulations, to consider the impact of those regulations on small entities. In the Proposal, the Commission certified that the Proposal would not have a significant economic impact on a substantial number of small entities.
The Commission has previously determined that CPOs are not small entities for purposes of the Regulatory Flexibility Act.
Accordingly, the Chairman, on behalf of the Commission, hereby certifies pursuant to 5 U.S.C. 605(b) that the Final Rule will not have a significant economic impact on a substantial number of small entities with respect to CPOs.
2. IBs and CTAs
The Commission has previously determined to evaluate within the context of a particular rule proposal whether all or some IBs or CTAs should be considered to be small entities and, if so, to analyze the economic impact on them of any such rule.
Since there may be some small entities that are IBs or CTAs and would be required to become NFA members, the Commission has considered whether this rulemaking would have a significant economic impact on these entities.
The Final Rule requires all IBs and CTAs, except § 4.14(a)(9) Exempt CTAs, who register with the Commission to become RFA members. This would require such IBs and CTAs to pay membership dues, “check a box” on Form 7-R, and ensure that they are prepared for an NFA audit.
As noted in the Proposal, the Commission is of the view that any costs associated with preparing for an audit by the NFA should not be substantially different from, or significantly exceed, the costs associated with preparing for an audit by the Commission, which every registered person would already be responsible to do.
Moreover, because the Final Rule only pertains to Commission Registrants, any audit related costs incident to NFA membership would be negligible, and should not have a significant economic impact on IBs or CTAs that may be small entities. The Commission also stated its preliminary belief that NFA membership would impose few additional compliance costs on affected entities, because these entities are already subject to the majority of regulations that NFA enforces, whether or not they are NFA members. The Commission specifically requested comment on any additional compliance costs beyond those an entity would face as a result of it being registered with the Commission.
a. Comments on Costs to CTAs
In response to the Proposal, a comment from Lovely stated that most CTAs that opt into CFTC registration and do not manage or exercise discretion over customer accounts or funds are “small or one-person operations or may have only incidental involvement with commodity interests.” Further, Lovely asserts that, although many of NFA's rules are not relevant to such CTAs, the Commission understates the cost of required NFA membership, including that the costs to these CTAs of reviewing and complying with such rules would be approximately $15,000 to $20,000 annually.
As discussed above, the Commission believes that Lovely's compliance cost estimates are very high. Rather, the Commission believes that the costs faced by a CTA would, at most, be approximately $2,950 in the first year and $1,476 in subsequent years.
The Commission does not believe that these amounts plus the $750 membership dues required of all NFA members that are CTAs, results in an unreasonable burden on any CTAs (including those that may be small entities under the Regulatory Flexibility Act).
Further, as Start Printed Page 55027discussed above, § 4.14(a)(9) Exempted CTAs (i.e., those CTAs that neither manage nor exercise discretion over customer accounts or funds and that do provide clients advice described in § 4.14(a)(9)(ii)) will not be required to become or remain RFA members pursuant to the Final Rule and, thus, will not face any compliance costs from the Final Rule.
b. Commission Determination
Accordingly, for the reasons stated above, the Commission believes that the Final Rule will not have a significant economic impact on a substantial number of small entities. Therefore, the Chairman, on behalf of the Commission, hereby certifies, pursuant to 5 U.S.C. 605(b), that the Final Rule being published today by this Federal Register release will not have a significant economic impact on a substantial number of small entities.
C. Considerations of Costs and Benefits
Section 15(a) of the CEA requires the Commission to consider the costs and benefits of its actions before promulgating a regulation under the CEA or issuing an order. Section 15(a) further specifies that the costs and benefits shall be evaluated in light of the following five broad areas of market and public concern: (1) Protection of market participants and the public; (2) efficiency, competitiveness, and financial integrity of futures markets; (3) price discovery; (4) sound risk management practices; and (5) other public interest considerations. The Commission considers the costs and benefits resulting from its discretionary determinations with respect to the section 15(a) factors.
As discussed above, the Dodd-Frank Act amended the CEA to establish a comprehensive new regulatory framework for swaps markets and, in doing so, required IBs, CPOs, and CTAs acting in relation to swaps to register with the Commission. These newly registered persons, however, are not currently required to become NFA members because, as discussed above, they are not captured by the intersection of § 170.15 and NFA Bylaw 1101.
NFA cannot enforce its rules over Commission registrants who do not become NFA members, including IBs, CPOs, and CTAs active solely in relation to swap transactions, which are not currently required to become NFA members. Thus, the Final Rule requires registered IBs, CPOs, and CTAs, except § 4.14(a)(9) Exempted CTAs, to become NFA members similarly to how § 170.15 presently requires FCMs to become NFA members and how § 170.16 requires the same of SDs and MSPs. In conjunction with §§ 170.15 and 170.16, the Commission is intending to create an oversight regime that ensures more consistent treatment of its registered intermediaries. The Commission believes that the Final Rule is reasonably necessary to ensure the fitness and comprehensive regulation and appropriate oversight of such persons.
In assessing the costs and benefits of the Final Rule, the Commission employs a status quo baseline. The Commission analyzes the cost and benefit to those registered persons that, but for the Final Rule, would not have to become RFA members. As of June 30, 2015, the following numbers of Commission registered IBs, CPOs, and CTAs (registered in the below categories) were not NFA members (“Non-member Registrants”): 
|Registration category||Non-member registrants|
|IB & CPO||1|
|IB & CTA||2|
|CTA & CPO||41|
|FCM & CPO||1|
Of these Non-member Registrants, however, approximately 138 are pending withdrawal of their Commission registration. The Commission is assuming that these Non-member Registrants will withdraw their registration and, thus, will not be impacted by the Final Rule. In addition, only approximately one percent of the Non-member Registrants registered solely as CTAs reported to the Commission in the most recent reporting cycle that they had directed client accounts.
As such, the Commission believes that many of the Non-member Registrants registered solely as CTAs will be § 4.14(a)(9) Exempted CTAs and, thus, will not be required to comply with the Final Rule.
Accordingly, the Commission estimates that 296 
persons registered with the CFTC as a CPO, CTA, or IB will be required to become and remain NFA members as a result of the Final Rule.
Because at this time the Commission cannot reasonably estimate the number of Non-member Registrants that may deregister with the Commission as a result of the Final Rule, the Commission is assuming that no Non-member Registrants will deregister as a result of the Final Rule. The Commission believes that this will lead to an overstatement of the compliance costs relating to the Final Rule.
a. Costs to IBs, CPOs, and CTAs
As discussed above, the process for a Non-member Registrant to become an NFA member amounts to checking a box on the CFTC registration form and updating some contact information. Thus, the Commission believes the cost of filing for membership to be non-substantive.
Affected persons are also subject to certain membership fees. NFA imposes initial membership dues and annual membership dues for IBs, CPOs, and CTAs. Currently, such initial membership dues are $750 for the first year, and the annual dues to maintain membership are $750 per year Start Printed Page 55028thereafter.
Thus, the 296 affected Non-member Registrants, in the aggregate, will incur an initial and ongoing annual registration/membership cost of approximately $222,000.
The Commission agrees with Lovely that the Final Rule will also impose certain compliance costs on affected Non-member Registrants. However, as noted above, the Commission believes that, given the existing requirements imposed on such registrants, the compliance costs of becoming an NFA member and complying with NFA's rules (including preparing for an audit by NFA) will be partially offset by the costs already incurred by these registrants (i.e., the costs associated with complying with Commission regulations and preparing for examinations by the Commission). In that regard, as discussed above, the Commission disagrees with Lovely's cost estimates and estimates that an affected registrant may, at most, face additional compliance costs of approximately $2,950 initially and $1,476 in subsequent years, equating to an industry total of $873,200 in the first year and $436,896 in subsequent years,
plus the indirect costs of the periodic audits. The Commission cannot reasonably provide an exact estimate of these costs due to the idiosyncratic nature of the indirect costs incurred.
b. Other Market Costs
In addition to the direct costs to Commission Registrants, the Commission considered other costs to the markets of the Final Rule. In particular, the Commission considered the impact the Final Rule will have on IBs, CPOs, and CTAs (i) election to not register with the Commission and (ii) optional deregistration, in each case, where such persons are not required to be registered with the Commission. Further, the Commission considered that the requirements of the Final Rule may cause fewer persons to elect to become IBs, CPOs, and CTAs because of the added burden of being an RFA member. The Commission is unable to estimate accurately how many IBs, CPOs, and CTAs will deregister with the Commission or elect not to so register in the future, or how many persons will choose to not become such an intermediary, in each case, as a result of the Final Rule. Further, the Commission believes that if a market participant has chosen not to register with the Commission, the costs incurred by that participant for not registering would be less than the costs that would have been incurred to register. Otherwise, the market participant would likely have chosen to register instead. However, the Commission cannot make a more accurate determination of costs beyond this overestimate without knowing more specifics about a particular market participant.
c. Consideration of the Proposal as an Alternative to the Final Rule
The Commission believes the costs in a. and b. above, respectively, are reduced from those that would have resulted had the Proposal been adopted without modification (the Proposal would have required each registered IB, CPO, and CTA, without exception, to become and remain a member of an RFA), because the Commission has excepted § 4.14(a)(9) Exempted CTAs from the requirements of the Final Rule. This exclusion limits the Commission's ability to oversee these persons through delegation to an RFA; however, the Commission has determined that this reduction in the Commission's oversight abilities is reasonable in light of the burden that the Proposal would otherwise impose on § 4.14(a)(9) Exempted CTAs and the markets. The Commission further notes that, as discussed above, § 4.14(a)(9) Exempted CTAs that are not RFA members are still subject to the Commission's rules and regulations.
The Final Rule enables the Commission to (i) carry out its obligations pursuant to Section 17 of the CEA to delegate certain oversight responsibility for intermediaries, including IBs, CPOs, and CTAs, to an RFA, and (ii) ensure the fitness of its registrants as described under Section 4p of the CEA. The Commission believes that by requiring RFA membership, the Final Rule results in a more efficient deployment of agency resources which would otherwise have to be used to oversee these registrants who would, without the Final Rule, not be overseen by an RFA. Further, the Commission believes that the Final Rule enables NFA to apply its experience as a SRO to oversee and ensure the fitness of all registered IBs, CPOs, and CTAs, except § 4.14(a)(9) Exempt CTAs. The markets and the public will benefit from NFA's developed set of rules and oversight capabilities to ensure the integrity of the swaps market and its participants.
4. Section 15(a) Factors
The Commission requested comment on all aspects of the Section 15(a) factors. Except as discussed above, the Commission did not receive any comments relating to costs and benefits of the Final Rule.
Section 15(a) of the CEA requires the Commission to consider the effects of its actions in light of the following five factors:
a. Protection of Market Participants and the Public
The Final Rule will protect the public by ensuring that registered IBs, CPOs, and CTAs, except § 4.14(a)(9) Exempt CTAs, are subject to the same level of comprehensive NFA oversight.
b. Efficiency, Competitiveness, and Financial Integrity of Markets
The Final Rule ensures that all registered IBs, CPOs, and CTAs, except § 4.14(a)(9) Exempt CTAs, are subject to a similar level of oversight and regulatory responsibility. In so doing, the Commission believes the integrity of markets is enhanced. Furthermore, the Commission also believes that the Final Rule will promote public confidence in the integrity of derivatives markets by ensuring consistent and adequate regulation and oversight of registered IBs, CPOs, and CTAs, except § 4.14(a)(9) Exempt CTAs.
c. Price Discovery
The Commission has not identified an impact on price discovery as a result of the Final Rule.
d. Sound Risk Management
The Commission has not identified an impact on the risk management decisions of market participants as a result of the Final Rule.
e. Other Public Interest Considerations
The Commission has not identified an impact on other public interest considerations as a result of the Final Rule.
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- Authority delegations (Government agencies)
- Commodity futures
- Membership in a Registered Futures
For the reasons stated in the preamble, the Commodity Futures Trading Commission amends 17 CFR part 170 as set forth below:
PART 170—REGISTERED FUTURES ASSOCIATIONS
Start Amendment Part
1. The authority citation for part 170 is revised to read as follows: End Amendment Part
Start Amendment Part
2. Add § 170.17 to read as follows: End Amendment Part
Introducing brokers, commodity pool operators, and commodity trading advisors.
Each person registered as an introducing broker, commodity pool operator, or commodity trading advisor must become and remain a member of at least one futures association that is registered under Section 17 of the Act and that provides for the membership therein of introducing brokers, commodity pool operators, or commodity trading advisors, as the case may be, unless no such futures association is so registered; provided, however that a person registered as a commodity trading advisor shall not be required to become or remain a member of such a futures association, solely in respect of its registration as a commodity trading advisor, if such person is eligible for the exemption from registration as such pursuant to § 4.14(a)(9) of this chapter.
Issued in Washington, DC, on September 9, 2015, by the Commission.
Christopher J. Kirkpatrick,
Secretary of the Commission.
The following appendix will not appear in the Code of Federal Regulations.
Appendix to Membership in a Registered Futures Association—Commission Voting Summary
On this matter, Chairman Massad and Commissioners Bowen and Giancarlo voted in the affirmative. No Commissioner voted in the negative.
End Supplemental Information
[FR Doc. 2015-23046 Filed 9-11-15; 8:45 am]
BILLING CODE 6351-01-P