Dear Members – The NIBA submitted our comment letter to the NFA regarding its capital requirement proposal for CTAs and CPOs and other changes to the CTA registration status. We are firmly opposed to capital requirements for CTAs and to the elimination of registration status for the group of current CTAs which NFA refers to as “inactive.” NIBA believes CPO criteria may be quite different than that for CTAs, and should be considered separately. The full text of our submission is found in this newsletter. We understand the NFA is considering all the submissions — we hear there were many….