March 16, 2016 Mr. Christopher J. Kirkpatrick Secretary of the Commission Commodity Futures Trading Commission Three LaFayette Centre, 1155 21st Street, NW Washington, DC 20581 RE: Proposed Rulemaking on Regulation Automated Trading (“Reg AT”) RIN 3038-AD52 VIA ELECTRONIC SUBMISSION Mr. Kirkpatrick: NIBA appreciates the opportunity to comment on the Commodity Futures Trading Commission’s (“Commission” or “CFTC”) proposed rulemaking on Regulation Automated Trading (“Reg AT”). Founded in 1991, NIBA is a trade association of registered derivatives professionals whose members include Introducing Brokers (“IBs”), Commodity Trading Advisors (“CTAs”) and Associated Persons. Our members handle transactions for customers in the futures, options, forex…