The Futures Industry Association, on behalf of its member firms and similarly situated futures commission merchants and introducing brokers (each, a “Firm”), respectfully requests the staff of the Commodity Futures Trading Commission (“Commission”) to confirm that it will not recommend that the Commission initiate an enforcement action against a Firm, if the Firm, in complying with its obligations under the customer identification rule (“CIP Rule”), relies on certain commodity trading advisors (“CTAs”) to perform elements of the Firm’s customer identification program notwithstanding that such CTAs currently are not subject to an anti-money laundering program rule under 31 USC 5318(h) (“AML Rule”) for the purposes of paragraph (b)(6) of the CIP Rule.
