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Commodity Futures Trading Commission |
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Division of Clearing and Intermediary Oversight |
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| Part I- CFTC Regulation 1.25- Investment of Customer Funds |
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| Name of Respondent: |
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| National Futures Association Number: |
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| 1. Please provide the following information pertaining to your direct investment of customer |
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| funds in permitted investments under Regulation 1.25(a)(1)(i)-(viii) as of November 30, 2007 |
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| (your response should include permitted investments that are subject to a repurchase agreement): |
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| Type of Investment |
Approximate Dollar Amount |
Percentage of Total Regulation 1.25 Direct Investments |
| US Government Securities |
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| Municipal Securities |
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| Government-Sponsored Enterprise Securities |
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| Certificates of Deposit |
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| Commercial Paper |
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| Corporate Notes or Bonds |
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| General Obligations of a Sovereign Nation |
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| Money Market Mutual Funds |
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| Total |
$0 |
0.00% |
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| 2. For the period from December 1, 2006 through November 30, 2007, did you engage in repurchase transactions using customer |
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| cash or securities purchased with customer cash, as permitted by Regulation 1.25(a)(2)(i)? |
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| Yes |
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| No |
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| If so, please provide the following information pertaining to reverse repurchase agreements (cash out, securities in) |
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| and repurchase agreements (securities purchased with customer cash out, cash in), as of November 30, 2007: |
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| Type of Investment |
Approximate Dollar Amount |
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| Reverse Repurchase Agreements |
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| Repurchase Agreements |
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| Total |
$0 |
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| For reverse repurchased agreements, as permitted by Regulation 1.25(a)(2)(i), please provide the following |
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| information regarding the securities obtained in the transactions, as of November 30, 2007: |
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| Incoming Securities |
Approximate Dollar Amount |
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| US Government Securities |
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| Municipal Securities |
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| Government-Sponsored Enterprise Securities |
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| Certificates of Deposit |
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| Commercial Paper |
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| Corporate Notes or Bonds |
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| General Obligations of a Sovereign Nation |
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| Total |
$0 |
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| 3. For the period from December 1, 2006 through November 30, 2007, did you engage in in-house transactions permitted |
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| by Regulation 1.25(a)(3)(i)-(iii)? |
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| Yes |
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| No |
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| If so, please provide the following information pertaining to in-house transactions, as of November 30, 2007: |
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| Type of Investment |
Approximate Dollar Amount |
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| Regulation 1.25(a)(3)(i) (cash out, securities in) |
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| Regulation 1.25(a)(3)(ii) (securities for securities) |
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| Regulation 1.25(a)(3)(iii) (securities out, cash in) |
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| Total |
$0 |
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| For investments under Regulation 1.25(a)(3)(i) (cash out, securities in), please provide the following |
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| information, as of November 30, 2007: |
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| Incoming Securities |
Approximate Dollar Amount |
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| US Government Securities |
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| Municipal Securities |
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| Government-Sponsored Enterprise Securities |
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| Certificates of Deposit |
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| Commercial Paper |
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| Corporate Notes or Bonds |
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| General Obligations of a Sovereign Nation |
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| Total |
$0 |
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| For investments under Regulation 1.25(a)(3)(ii) (securities for securities), please provide the |
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| following information, as of November 30, 2007 |
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| Incoming Securities |
Approximate Dollar Amount |
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| US Government Securities |
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| Municipal Securities |
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| Government-Sponsored Enterprise Securities |
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| Certificates of Deposit |
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| Commercial Paper |
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| Corporate Notes or Bonds |
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| General Obligations of a Sovereign Nation |
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| Total |
$0 |
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| 4. For the period December 1, 2006 through November 30, 2007, did you directly or indirectly invest in any instruments that contain an |
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| embedded derivative, as permitted under Regulation 1.25(b)(3)(i)? |
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| Yes |
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| No |
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| 5. For the period December 1, 2006 through November 30, 2007, did you directly or indirectly invest in any adjustable rate securities, |
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| as permitted under Regulation 1.25(b)(3)(iv)? |
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| Yes |
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| No |
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| 6. Does the information provided in your responses to questions 1 through 5 as of November 30, 2007, substantially reflect your overall |
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| investment strategy for the period from December 1, 2006 through November 30, 2007? If not, please describe how it differs. |
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| 7. Please indicate in which types of investments, as permitted by Regulation 1.25(a)(1)(i)-(viii), you directly invested at any time |
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| during the period from December 1, 2006 through November 30, 2007: |
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| Type of Investment |
Did you invest? |
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| US Government Securities |
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| Municipal Securities |
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| Government-Sponsored Enterprise Securities |
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| Certificates of Deposit |
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| Commercial Paper |
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| Corporate Notes or Bonds |
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| General Obligations of a Sovereign Nation |
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| Money Market Mutual Funds |
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| 8. For the period from December 1, 2006 through November 30, 2007, did you intentionally limit your Regulation 1.25 investments |
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| to those that were acceptable to clearing organizations as margin deposits? |
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| Yes |
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| No |
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| Part II- CFTC Regulation 30.7- Investment of Secured Amounts |
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| 9. Please provide the following information pertaining to your direct investment of secured amounts under Regulation 30.7, |
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| as of November 30, 2007 (your response should include securities that are subject to a repurchase agreement): |
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| Type of Investment |
Approximate Dollar Amount |
Percentage of Total Regulation 30.7 Investments |
| US Government Securities |
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| Municipal Securities |
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| Government-Sponsored Enterprise Securities |
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| Certificates of Deposit |
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| Commercial Paper |
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| Corporate Notes or Bonds |
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| General Obligations of a Sovereign Nation |
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| Money Market Mutual Funds |
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| Other (see question 10) |
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| Total |
$0 |
0.00% |
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| 10. Please provide the following information pertaining to additional investments of secured amounts, not otherwise identified |
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| in question 10 above, as of November 30, 2007: |
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| Type of Investment |
Approximate Dollar Amount |
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| Total |
$0 |
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| 11. For the period from December 1, 2006 through November 30, 2007, did you engage in repurchase transactions with |
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| securities purchased with secured amounts? |
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| Yes |
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| No |
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| 12. For the period from December 1, 2006 through November 30, 2007, did you directly or indirectly invest in any instruments that contain an |
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| embedded derivative (e.g., a call option, or interest cap, floor or collar)? |
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| Yes |
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| No |
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| 13. For the period from December 1, 2006 through November 30, 2007, did you directly or indirectly invest in any adjustable rate securities? |
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| Yes |
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| No |
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| 14. Does the information provided in your responses to questions 9 through 13 as of November 30, 2007, substantially reflect your overall |
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| investment strategy for the period from December 1, 2006 through November 30, 2007? If not, please describe how it differs. |
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| Part III- Additional Comments |
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| 12. Please provide any additional comments which might assist the CFTC in understanding your investment strategies and |
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| evaluating requirements applicable to the investment of customer funds and secured amounts. |
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