Mr. Christopher J. Kirkpatrick September 2, 2014 protection measure to require FDMs to also verify daily that they have sufficient funds to meet their liability to forex customers. Therefore, NFA is amending NFA Financial Requirements Section 14 to require each FDM to instruct each qualifying institution that holds assets used to cover its liabilities to retail forex customers to report daily the balances in these accounts to NFA or a third party designated by NFA.

The proposed amendments also specify that in order to be an acceptable qualifying institution to hold assets covering an FDM's liabilities to retail forex customers, the qualifying institution must report the balances in the FDM's accounts to NFA or a third party designated by NFA. As mentioned earlier, NFA is invoking the “ten-day” provision of Section 17(j) of the Commodity Exchange Act. NFA intends to make the proposed amendments to NFA Financial Requirements Section 14 regarding daily confirmation of funds covering liabilities to retail forex customers effective ten days after receipt of this submission by the Commission, unless the Commission notifies NFA that the Commission has determined to review the proposal for approval. Respectfully submitted, Thomas W. Sexton Senior Vice President and General Counsel *The proposed amendments to NFA Financial Requirements Section 14 became effective October 15, 2014. 3 .