Dear NIBA Member: On August 8, 2011, the Association filed a comment letter relating to the Proposed Amendment to CFTC Regulation 1.35(a). This proposed amendment goes beyond the NFA Rule which requires firms with a certain number of disciplined APs to record conversations with clients. The CFTC proposal would require every IB to record all oral and written communications with a client or potential client which lead to a transaction. After receiving member comments, the NIBA Board of Directors filed our Association comment letter vigorously opposing the proposed amendment. You can view the comment at http://comments.cftc.gov. Look for the comments…