September 10, 2012 Ira Bodenstein, Trustee for PFG Best By Email Only – [email protected] Mr. Bodenstein: I write on behalf of the National Introducing Brokers Association (NIBA). Founded in 1991, the NIBA is a membership association of futures and options professionals registered primarily as Introducing Brokers (IBs). I write with regard to a specific distribution method your office proposed last week in the Peregrine Financial Group (PFG) bankruptcy, Docket Document #147: a proposal to make a bulk transfer of futures customers accounts with an interim distribution of funds, all to a qualified “acquiring FCM.” It seems to us that the…