|
Click here for a printer-friendly version of the transcript.
LARRY DYEKMAN, DIRECTOR OF COMMUNICATIONS AND EDUCATION, NFA: Good afternoon. Welcome to NFA's audio conference on recent regulatory developments.
We're a little late getting started because of some AT&T technical problems, and we apologize. We're glad you could join us.
My name is Larry Dyekman, and I am the Director of Communications and Education at NFA.
This afternoon, you will hear from four NFA staff members on a variety of topics. After all four of the presentations have been completed, we will have a question-and-answer session. You will be given instructions at that time on how to indicate to the conference coordinator that you would like to ask a question.
We've also placed a short feedback form in the member in education and training (ph) section of our Web site. This is NFA's first audio conference, and we want to know what you think about it. Please take a few minutes after the conference to complete the form and e-mail it to us. Your feedback is important to us and will provide us with valuable information for future conferences.
Our first speaker today is Dan Roth, Senior Executive Vice President and Chief Operating Officer at NFA. Dan will discuss the recent restructuring of NFA's board of directors and NFA's changing role in the futures industry.
Dan.
DAN ROTH, SENIOR EXECUTIVE VICE PRESIDENT, CHIEF OPERATING OFFICER, NFA: Thanks, Larry.
And I'd like to just repeat what Larry said. Thank you all for giving us a couple minutes out of your busy day.
So that we can try to make sure that you're up-to-date on some of the developments at NFA that we think will be of interest to you, what we'd like to cover today is a variety of topics. One thing we'd like to talk about are all the activities that we've engaged in regarding single-stock futures, and how that product's going to come about, and what NFA's regulatory role will be with respect to that product.
We'd also like to talk to you about a new registration system, our electronic registration system, which we're developing and will be implementing next year — which we think will streamline and facilitate the registration process for everybody.
And we'd like to talk about the electronic filing of financial statements, which is again trying to find a way where you can do business a little bit more easily and we can do business a little bit more easily and more cost effectively.
Before we talk about those developments, though, I'd like to take a few minutes, and try to place them in an overall context of how NFA as an organization is changing, and where we're trying to go as an organization.
NFA is of course a self-regulatory body for the futures industry. And in some ways, we're a creature of Congress, we're a creature of statute. The Commodity Exchange Act gave a fairly sweeping array of responsibilities for National Futures Association. Last year, Congress added considerably to those responsibilities by giving us a very pivotal role with respect to single-stock futures.
So we're a creature of statute. But we realize that to really thrive as an organization — for us to really do the maximum job that we can do, to operate in the best way we can for our members — that we can't just rely on the statute to justify our existence. We can't justify our existence by pointing to a statute and saying NFA exists because this statute says we have to.
We feel that we have to be able to add value, and to be able to demonstrate to everybody that we do add value to the marketplace. We have to be able to demonstrate that to our board, to our membership, to the CFTC, now to the SEC, and ultimately to the Congress.
In short, what we're really trying to do is transform this organization from just being a regulator to being a service provider. Because that's what we think the essence of our job is: to be a regulatory service provider. And like any service provider, we know that we have to provide services that our customers really need. We have to provide those services at the highest possible quality and at the lowest possible price.
Like any service provider, we have to keep finding new services to perform for our customers, and new ways of performing the services that we already perform. And that's a big part of what we're talking about here today.
But another part of being a service provider is that we need customer feedback. And we need it a lot.
We get plenty of feedback from the CFTC. There is a customer that we just get feedback from all the time. We get plenty of feedback from our board of directors. We have been getting a lot of feedback from the SEC, and we try in as many ways as we can to get feedback from the members. And that's certainly what this forum is about today.
But we don't need a forum to do that, and we don't need town hall meetings. All of us at NFA have phones right there on our desks. And any one of you can call me at any given time. My direct number is 312-781-1390. We need to hear from you, and I need to hear from you. If you've got a problem, if you've got a suggestion, if you've got an idea about a better way that we can do our job, we very much want to hear that.
The second point I wanted to cover, besides placing everything in context of how we're trying to change the organization into a real service provider was our board of directors elections that are coming up in the next couple of weeks.
And as Larry mentioned, we've restructured our board. I don't know if you noticed it in the mail that you received from NFA, but we've restructured our board to go from a board of directors of 45 people down to a board of directors of 25. And we think that that move is designed to ensure that NFA is able to adjust quickly to a quickly changing business environment; that we're in a position to make decisions in as streamlined and efficient a means as possible.
One result of that is, as we move from 45 to 25, the election process this year is going to be different than it's been in the past. I think there's a much greater likelihood of contested elections this year in all the categories — for FCMs, CPOs, CPAs and IBs.
And I would just ask you to very carefully consider your ballots when they're mailed out to you, I think in early December. Within the next few weeks, the petition process will be closed. We'll know who all of the candidates are. We'll send the ballot out.
And I would ask you to take some time and really reflect on your ballots this year. Because it's a very important election as we make this transformation from a 45-person board to 25. And you play a pivotal role in that process. And I hope you'll take time, and really exercise your franchise, and do it in a thoughtful and deliberate way.
Those are the two points I wanted to cover. And now maybe we can start talking about some of the specific points, Larry.
DYEKMAN: Thanks, Dan. For those of you who may have joined this program in progress, this is NFA's audio conference on recent regulatory developments.
Our next speaker is Regina Thoele, an Associate Director in Compliance. Regina will give you an update on security futures products. Regina?
REGINA THOELE, ASSOCIATE DIRECTOR IN COMPLIANCE: Thank you, Larry.
First of all, I want to say that we know there's a lot of interest among our members in security futures products. There are also a lot of questions. Because I have just a short amount of time today, I will only be able to give you a brief overview on the subject. However, NFA will be offering half-day workshops on security futures products in Chicago and New York in January of 2002. These interactive workshops will take a comprehensive look at the new rules, and how members will apply them to not only their existing operations but also to the future operations. During the workshops, we will walk through actual steps you will need to take, such as changes to customer account agreements, addressing insider trading rules, and other important rule changes. We hope you will be able to attend.
Under the Commodity Futures Modernization Act of 2000, all security futures transactions are considered both securities and futures, regardless of whether they are traded on futures exchanges or security exchanges. Before these products could trade, NFA was required to qualify as a limited-purpose national securities association, so that we could regulate the activities of NFA members who notice register as broker-dealers in order to trade security futures products.
To qualify, NFA had to have customer protection and sales practice rules that were reasonably comparable to those of the NASDR's. After meeting with the SEC, we reviewed our existing rules. And while they were fairly comparable, there were a few areas where we needed to amend them. In the end, we adopted one new rule and three new interpretive notices. NFA submitted the proposed rules to the CFTC. And on August 20th, we received notice from the CFTC that it had approved the amendments. The amendments, which were also submitted to the SEC, became effective upon CFTC's approval. With the approval of these rules, NFA met the obligations that regulators required it to meet by August 21st, paving the way for the trading of security futures products on a principal-to-principal basis. We are still working with CFTC, the SEC and other SROs on additional issues that must be resolved before the date for retail trading of these products.
Now, I'm just going to touch on some of the major issues regarding the new rules.
First is registration. NFA member FCMs and IBs that intend to offer security futures products will need to passport into broker-dealer registration by completing the SEC form BD-N. This form, which can be found on NFA's Web site, should be filed with NFA, who will process the form on behalf of the SEC. An NFA member who passports into broker-dealer registration is not considered an NASDR member. While our member FCMs and IBs have specific registration requirements, their respective APs do not have to register with the SEC or the NASDR. They do, however, have to meet proficiency requirements.
Current APs can meet the proficiency requirements by taking an appropriate training course before they begin to solicit for these products. The training course must cover the subject matter included in a content outline that has been jointly developed by NFA, the NASDR and other DSROs.
NFA is in the process of developing one such training program. The training program, which will be web-based, is a joint effort by NFA, the NASDR and the Futures Industry Institute. Current registrants can take our training program in order to satisfy their training requirements. Our program will be available through our web site in the near future, at no charge to our members.
Every member passporting into broker-dealer registration must have at least one designated security futures principal at each main or branch office that engages in securities futures activities. In order to be designated as a security futures principal, these people will be required to take a portion of the training program which is devoted to supervisory issues, as well as the portions intended for all APs.
NFA members and associates are not required to notify NFA that they have completed a training program. But members should be able to demonstrate to NFA during an audit that those individuals offering security futures products have completed the necessary training. For example, members could keep records of associates who attended internal training programs, or require associates to provide certificates of completion for outside training programs. NFA will be providing each individual who takes our program with a certificate reflecting that they have completed the program.
The second area I would like to address deals with account openings, suitability of transactions, and the disclosure statement.
NASDR rules require members to specifically approve accounts for trading and prohibit members from making unsuitable recommendations. We have amended part of our Compliance Rule 2-30, and have also added a new section J, which includes these NASDR requirements and applies only to security futures products.
Let me briefly discuss some of those changes. Under NFA Compliance Rule 2-30(c), members must obtain additional information for any customer that wants to trade security futures products. Some of this information includes documenting whether the account is for hedging or speculative purposes, and the customer's employment status.
The new subsection J will include some of the additional steps a member must now take if their customers are going to trade these products. For example, a member needs to learn some essential facts about the customer, such as their investment objectives and financial situation. And based on those facts, the member must approve or disapprove the account in writing. The member is also required to verify with the customer that background and financial information upon which they approve the accounts. The same requirement applies if the member becomes aware of any material change in a customer's financial status.
As NFA members, you are familiar with our "Know Your Customer" rule. However, if you're going to offer security futures products to your customers, you will have to address suitability requirements. Under our new rule, an FCM or IB cannot recommend a transaction in security futures products to a customer without reasonable grounds for believing that the recommendation is not unsuitable for the customer based on the customer's current investment objectives, financial situation and needs. Additionally, a member cannot make a recommendation unless they believe the customer is reasonably capable of evaluating the risk of the recommended transaction, and is financially able to bear that risk.
As part of the account-opening process, all members will be required to provide the customer with a disclosure statement for security futures products at or before the time the member approves the account for trading. NFA is working jointly with the NASDR and other DSROs to develop a uniform disclosure statement. While members are not required to obtain an acknowledgment of receipt from the customer, they must, again, during an audit, be able to demonstrate that they provided the customer with a disclosure statement.
Now let's move on to promotional material.
Again, this is an area where NFA is drafted an additional section to our already-existing promotional material rules. While NFA's and the NASDR's promotional material rules are comparable for the most part, the NASDR rules contain several requirements that were not explicitly stated in our rules.
The new subsection J of NFA Compliance Rule 2-29 applies only to promotional material that specifically refers to security futures products. Some of the points contained in this rule are procedural. For example, the promotional material must prominently identify the member, include the date the material was first used, and state explicitly that security futures products are not suitable for all customers.
I'd like to mention three of the more substantial changes to our promotional material rule. First, the rule prohibits promotional material from referring to past trading recommendations in the security futures or related products, unless it describes all other recommendations made for similar products over the last year unless it describes all other recommendations made for similar products over the last year. Second, the rule prohibits promotional material from making specific trading recommendations, unless the material discloses conflicts of interest based on activities in the underlying security and offers to provide information regarding all recommendations made for similar products over the last year. And finally, the rule requires members to pre-file all mass media ads, unless it merely mentions security futures products as one of the services it offers.
The last area I would like to touch on covers the fair dealing requirements. Both NFA and the NASDR have rules prohibiting their respective members from engaging in conduct inconsistent with just and equitable principles of trade, as well as manipulative or fraudulent practices. The NASDR, however, has several interpretive memos, which specifically address the exact conduct that is prohibited. Although that conduct is prohibited under our rules, but is not specifically detailed, we drafted a notice that defines what is prohibited.
One of the areas addressed in the notice is the concept that brokers may not trade ahead of customer orders. Most, if not all, futures exchanges have rules prohibiting their members from this conduct. CFTC regulations require FCMs and IBs to have and enforce procedures to ensure that they and their employees do not trade ahead of customer orders. Although NFA does not have a specific requirement prohibiting members and associates from trading ahead of customer orders, we have always considered it a violation of our Compliance Rule 2-4. However, in order to make our rules more comparable to the NASDR, we have specifically prohibited that conduct in this new, interpretive notice.
The interpretive notice also contains several provisions that apply only to our passported members who offer security futures products. These provisions: (1) prohibit trading ahead of research reports; (2) prohibit trading based on knowledge of an imminent block transaction, with an exception, of course, for hedging risks if allowed by exchange block rules; and finally, (3) require a sound basis for evaluating the facts regarding a particular security futures product.
There are a couple of other issues which we are still working on with the SEC. These areas include best execution and fair commissions. These issues will be resolved before retail trading in these products begins. Finally, I want to encourage everyone to attend one of the member workshops we will be offering. These workshops will address in more detail the changes and how they impact your firm. Please review our Web site for more information on the workshops. Further, if you have questions, please feel free to call me, Regina Thoele at (312) 781-1327.
Thank you much.
ROTH: Larry, before you move on, can I just ask a question? Regina, any time we're talking about rules, it gets pretty detailed. And that's a lot of stuff to try to absorb over the telephone. Are the rules themselves and the text of the rules that we've submitted to the CFTC on the Web site?
THOELE: They are.
ROTH: And people could go there to our Web site, and really look at those rules, and the explanations of the rules, to try to back up some of the information that you just provided verbally.
THOELE: The rules are there, the interpretative notices are there. And as Dan just said, there is an explanation, which is very detailed and walks through each step that we took and each change that we made. And that would be a great resource for you to look at.
DYEKMAN: Thank you. I would like to remind listeners that there will be four speakers this afternoon, followed by a question-and-answer session. Our next speaker is Bob Krewer, another Associate Director in Compliance. Bob will discuss recent developments in the area of electronic filing of financial statements.
BOB KREWER, ASSOCIATE DIRECTOR IN COMPLIANCE: Thanks, Larry.
In the compliance department, we have as one of our responsibilities the requirement to ensure capital compliance of our members in regards to both our rules and the CFTC's capital requirements. We do this in part for the review of financial statements. These statements are submitted to us on a regular basis. Firms that are registered as independent Introducing Brokers and firms that are registered as Futures Commissions Merchants are required to file financial statements with us and with the CFTC.
These firms file their financial statements either in paper form, or electronically for our electronic filing system. We have offered electronic filing to you for over three years. You are allowed to file electronically. But to date, filing electronically has been entirely optional.
We have been working on designing a new electronic filing system with the intent that all firms will be required to file their financial statements electronically. Currently, all IBIs and FCMs are required to file their financial statements with their designated self-regulatory organization and the CFTC.
We've noted that when comparing electronically filed statements with paper filings over the last three years that there are considerable advantages to the electronically filed financial reports. For one, you are able to import directly through your general ledger. Also, the software automatically foots, cross foots and totals balances for you. The software saves your filings electronically, providing you with fingertip access to all of your financial statements. NFA also confirms to you electronically, almost instantly, that the statement was received. Electronically filed financial statements are received sooner after the month's end than paper filings. As such, our reviews begin sooner, while the data's more current. Electronically filed financial statements are also more accurate. The software detects clerical errors before the statements are filed. The software informs you of the errors, and in fact will not allow a statement to be filed if certain balances do not equal. Because the filings are more accurate, we are able to complete our review more quickly.
Currently, we accept electronically filed financial statements using software known as iNFAst. iNFAst is our electronic filing system. Exchange members have been filing their financial statements with the exchanges using a platform known as WinJammer. With two electronic filing systems within the futures industry, there are obvious concerns from those firms which file using both systems. The current WinJammer software does not include the Focus 2A or 1FR-IB forms. And the CFTC does not currently accept iNFAst filings.
Therefore, in an effort to bring uniformity to the industry, NFA has been working with the Chicago Mercantile Exchange and Chicago Board of Trade over the last six months in an effort to design a single filing platform. This system will be known as WinJammer IV. WinJammer IV will allow independent IBs and FCMs - even if they are broker dealers — to file their financial statements electronically with the CBT the CME the CFTC and us. This single platform will allow you to file with any of us, or all of us, instantly and simultaneously.
Currently, the WinJammer software is licensed by several entities, including the Chicago Board of Options Exchange, the Midwest Stock Exchange, Federal Reserve Bank of New York, and the New York Mercantile Exchange. These entities will also receive the new WinJammer IV) software.
WinJammer IV, when completed, will include the following forms: the CFTC form 1FR-IB and 1FR-FCM, and the SEC forms Focus II and Focus IIA for broker-dealers. WinJammer IV will also provide the downloading of Focus 2 and 2A forms from New York Stock Exchange files and from NASD files. This import feature will eliminate the need to type in the financial information from those filings. Once imported, this data, just like type data, can be transmitted to the appropriate organization.
The WinJammer IV software will be provided to you beginning in mid December. NFA, the CME and the CBC will mail out disks with the software to each of you. All you will need to install WinJammer IV software is Microsoft Windows 95 or a later version of Windows. Once installed, the software's ready for use. In order to submit a financial statement electronically, you must have a personal identification number. The PIN system will be uniform throughout the industry. Firms that file with us will receive paperwork for PINs beginning in late November. The PIN allows us to identify who is sending the financial statement. The PIN will also substitute the signature on the attestation that was required on paper filings.
WinJammer IV prepared statements are encrypted using 128-bit encryption software before being transmitted. When transmitted, the encrypted statements are sent via the Internet. You indicate where you want the statement sent, and then transmit the statement. We currently send an electronic affirmation back to you. This confirmation indicates when your filing was received by NFA.
Our current time line has WinJammer IV rolling out in December. Our Executive Committee has approved — and our Board of directors will review in a couple of weeks — a change in NFA financial requirements to require all financial statements filed after December 1st to be filed electronically. Those filings will be required to be made using WinJammer IV software. Currently, the CFTC accepts WinJammer filings, and we anticipate a smooth transition to WinJammer IV. This will allow all filers to file electronically with the CFTC as well. This should eliminate all paper filings within the futures industry, with the exception of certified financial statements which CFTC regulations currently prohibit from being filed electronically.
Also, our Executive Committee is recommending to the Board of Directors that all FCMs be required to file their financial statements monthly. Currently, exchange member FCMs are required to file monthly. This change will bring additional uniformity to the futures industry.
I'd like to add that we will work with each of you. We recognize that there may initially be some technical difficulties with your use of the new software, or even with our system. We will work with you to get the filings in electronically. We will, however, understand if it doesn't work the first time due to technical difficulties, and we will accept paper filings if all other attempts fail. We are also looking at receiving certified financial statements electronically, and also receiving financial statements electronically from Commodity Pool Operators at some point in the future.
I'd like to thank you for your time today. I look forward to answering any questions you might have during the question-and-answer session. I will now turn the microphone back over to Larry.
DYEKMAN: Thanks, Bob.
Our final speaker is Greg Prusik. Greg is the Vice President of Registration and Compliance at NFA. Greg will give you a status report regarding NFA's upcoming electronic registration system.
Greg?
GREG PRUSIK, VICE PRESIDENT OF REGISTRATION AND COMPLIANCE, NFA: Thanks a lot, Larry.
I'd like to spend a few minutes talking about NFA's plans for a new Web-based registration system. We're calling the system e-Registration. This is a system that will enable registrants and applicants to make all of their CFTC registration and NFA membership filings over the Internet.
Before telling you about e-Registration, it might be helpful to briefly recap some of NFA's history of utilizing technology in the registration area. NFA's been operating an electronic registration filing system since 1990. In fact, we were the first financial services regulator to operate an electronic registration filing system. For nearly 12 years, our member firms have had the option of making AP filings electronically by connecting via telephone modem to our current mainframe system. Although the filing is electronic, we do require firms to follow up by sending us a hard copy paper form. And the hard copy form is the official record, which we maintain here at NFA.
Over 20 percent of all AP temporary licenses are granted through this electronic filing system. And more than 25 percent of all AP terminations are filed on it. And currently, 43 of our member firms use this system. And over the years, we've received more than 40,000 filings electronically.
In addition to our 12 years of experience with electronic registration filing, we also have experience with utilizing Internet technology in the area of registration.
Our Background Affiliation Status Information Center, a system that we call BASIC, has been in operation for more than two and a half years. This system makes a wealth of public information about registrants available to anybody who has Internet access. Additionally, BASIC makes us the only financial services regulator in the world that makes industry-related disciplinary action information available over the Internet. Customers and member firms have found BASIC to be a very useful tool, and the system averages 35,000 searches each month.
So from my point of view, NFA's development of an Internet-based registration system is not really a giant leap forward for us. It's more like the next logical step in a progression that's been going on for more than a decade.
As you may know, the NASDR has an Internet-based registration system called Web CRD, CRD standing for Central Registration Depository. This system was put into production about two years ago. Use of their system is mandatory for securities firms. However, like NFA's current electronic filing system, Web CRD is not a completely electronic system. Although securities firms make their registration filings via the Internet, the firms are required to keep hard copy paper forms on file as part of their records. In effect, the NASDR approach transfers the data entry function and the record retention function from NASD's staff to the staffs of the firms.
As I said before, NFA's current direct entry system is not completely electronic, either. Firms enter the information on the forms into our system and mail us the hard copy, which we maintain. So in effect, our current system transfers the data entry function to the firms. Even so, our current system was a big step forward in 1990, and it has served our members and us very well.
The e-Registration system that we are currently developing, however, is intended to be a truly paperless system. The electronic submission will be the filing of record. The official record will be the data in our database. The firm will not be required to keep a hard copy record of what was filed over the Internet. The firm will not yet send a hard copy of any form to NFA.
I'd like to briefly describe how this system will handle filings for associated persons and principals, since that's the part of the system that we're the farthest along with.
Here's basically how it will work. Firms will have the ability to create an electronic form, form 8-R, for an individual. The individual will then be given instructions from the firm on how to access this electronic form. And the individual would then complete the electronic form 8-R. I'd like to add the electronic form 8-R is a simplified form. The amount of background information requested has been reduced significantly, and we think we've made the disciplinary history questions much easier to understand.
After the individual completes the electronic form, the firm can review the information that was answered by the individual and submit the form to NFA over the Internet. The act of submitting the form to NFA is, in effect, the firm's certification of a filing. The firm will also have the ability to file updates as well as electronic terminations for any individual associated with it.
At this point, the only paper filings that will have to be filed for individuals after an electronic application has been submitted are the fingerprint cards and any documentation relating to "yes" answers to the disciplinary history questions. Fees can also be submitted after the fact, or the firm could elect to maintain a prepaid account with NFA. As all of the components of the system are developed, we will be evaluating alternative payment methods, such as credit cards and automatic funds transfers.
As I mentioned earlier, we're very far along in the development of the system for processing filings. And I have to say that from what I've seen to date, it's pretty good system. And I believe our members will really like it.
On the other hand, we're not very far along on the development of the portion of the system that will handle firm filing. So I probably shouldn't really talk too much about it at this point. But I do want to tell you that we are using similar approaches for firm filings, and we do intend for firm filings to be purely electronic as well.
Use of the e-Registration system will be mandatory. And our current timetable is to begin to implement the system in the second quarter of 2002. At this point, we just wanted to tell you a little bit about it, so that you can begin to think about how it might affect your operations. We certainly will be providing much more information as we go forward, and we'll be offering training opportunities as well in the coming months.
DYEKMAN: Thanks, Greg.
Before we open the conference up to questions, I just want to let you know that the written transcripts of this conference will be available on our Web site within the next few days. And if questions occur to you after this conference is over, please contact us, either through our Web site or you can call our Information Center at 800-621-3570.
So now let's open the conference up to questions. And you will now hear a prerecorded message, giving you instructions on how to alert the speaker that you have a question.
OPERATOR: This conference is now in question-and-answer mode. To alert the speaker that you have a question, press one, then zero. Each question will be asked in the order it was received.
DYEKMAN: Go ahead, please, with your question.
UNIDENTIFIED PARTICIPANT: Yes. I have a question about commodity pool operators again. I guess for Robert first, and for Greg as well, on electronic filing issues. I just want to clarify that CPOs do not, at this time, file electronically, or are not obligated to file electronically.
KREWER: That's correct. They are not required, not obligated, in fact, because commodity pool operators generally just file once, and it's a certified financial statement.
UNIDENTIFIED PARTICIPANT: OK. They're not allowed to at this point. And the follow-up question, then - these filings obligations, when ultimately they do apply to CPOs, but even currently, I'm assuming do not apply to filings made to the CFTC, correct?
KREWER: With regards to filing electronically?
UNIDENTIFIED PARTICIPANT: Right.
KREWER: Well, in fact, the Commission - and we have met with them informally several times — the intent is that they will receive it electronically as well, for IBIs and FCMs.
UNIDENTIFIED PARTICIPANT: So, if I understand it correctly, Bob, a firm would be able to file electronically one time, and really satisfy its filing obligations for both the NFA and the CFTC through that one filing.
KREWER: Correct. It will actually be sent to both places simultaneously.
UNIDENTIFIED PARTICIPANT: Perfect. OK. That's what I needed. Thank you.
KREWER: You're welcome.
DYEKMAN: Well, we don't have any more questions in the queue. So, we'll wait just a couple minutes in case you have. If you can think of a question, just hold on for a minute.
ROTH: And let me just say, while we're waiting for the questions, to — again, thank you for your patience. This is the first time we've done this, and I know we had some problems with the conference center that caused a delay this afternoon, and we regret that. And we'll try to work with them to make sure that doesn't happen again.
And we look forward to doing another one of these things soon. And we'll try to tinker with the format a little bit, based on the feedback we get, to try to make this as informative as possible.
DYEKMAN: OK. We're going to check and see if there are any questions.
UNIDENTIFIED PARTICIPANT: Hi. My question is about the workshops that are going to be put on by the NFA. I understand that the dates were changed to the first quarter of 2002. Just wanted to know what the length of the average workshop is going to be, how many days, and where they're going to be located.
THOELE: There will be two locations; one will be Chicago, and one (ph) will be New York. Right now, we're anticipating about a half-day session in each of the locations.
DYEKMAN: And these will be free of charge. And we will be having specific dates in the next couple weeks. We'll be posting it on the Web site and sending out registration notices in the next couple weeks.
ROTH: And can I ask one other thing, Larry? As far as educational programs that we're conducting for members, so that they understand what their obligations are for single-stock futures, the workshops are part of it. But we're also going to be doing a written piece of some type that'll be available on our Web site?
DYEKMAN: Right. We are producing a member's guide to security futures products that will recap all the rules and regulations that members would have to follow. And that will be available about the same time as the workshops are held in January. That will be on our Web site and can be downloaded from there.
UNIDENTIFIED PARTICIPANT: Great. I thank you.
DYEKMAN: OK. That's the last question we've got. So we'd like to thank you again for participating today. And we look forward to seeing you again. Good afternoon.
|