by Email June 1, 2012 Mr. David Stawick, Secretary Commodity Futures Trading Commission Three LaFayette Centre 1155 21st Street, NW Washington, DC 20581 Re: CFTC Rule 1.71 – Conflict of Interest Policies and Procedures by Futures Commission Merchants and Introducing Brokers: Scheduled to be Effective June 4, 2012 Mr. Stawick: I write in behalf of the National Introducing Brokers Association (NIBA). Founded in 1991, the NIBA represents Introducing Brokers, Commodity Trading Advisors and Associated Persons who are primarily engaged in the retail sector of the futures and options business. NIBA, a not-for-profit association, also has the support of 11 major…