External Meetings: Telephone Call with Delta Strategy Group

DSG representatives called on behalf of their state pension fund clients regarding the timing and approach to certification of independent representatives. ~ ~CFTC staff stated that the external Business Conduct Standards rules would likely be considered in fall 2011 and that staff is considering recommending a policies and procedures approach for Special Entities selection of independent representatives based on the statutory criteria, pending any future certification process that NFA or another body might develop.