APPENDIX A

The Commission has undertaken a number of major regulatory reform initiatives to modernize and streamline the regulatory regime it administers. Many of these initiatives resulted from industry proposals that were first raised during the legislative debate that occurred in this Subcommittee two years ago. Some of the many proposed and final rules issued in the last two and a half years include:

• Rule amendment adopting harmonized financial reporting requirements for CFTC registrants who are also registrants with the Securities and Exchange Commission ("SEC"). (62 Federal Register 4,633 (January 31, 1997).)

• Rule amendments to permit filing by large traders of CFTC Form 40, Statement of Reporting Trader, only when requested by the Commission rather than annually. (62 Federal Register 6,112 (February 11, 1997).)

• Rule amendments establishing streamlined "fast-track" procedures for processing contract market designation applications (62 Federal Register 10,434 (March 7, 1997)) and exchange rule amendments. (62 Federal Register 10,427, 10,434 (March 7, 1997).)

• Rule amendments permitting futures commission merchants ("FCMs") to file required financial reports with the Commission electronically. (62 Federal Register 10,441 (March 7, 1997).)

• Rule amendments allowing commodity trading advisers ("CTAs") and commodity pool operators ("CPOs") to file required disclosure documents with the Commission electronically. (62 Federal Register 18,265 (April 15, 1997).)

• Rule interpretation permitting streamlined procedures for allocation of customer orders which are bunched for execution by CTAs. (62 Federal Register 25,470 (May 9, 1997).)

• Advisory permitting FCMs to deliver monthly statements, trade confirmations and other account statements solely by electronic media to customers who consent to electronic transmission in lieu of receiving paper documents. (62 Federal Register 31,507 (June 10, 1997).)

• Rule amendments authorizing CTAs and CPOs to provide risk disclosure documents to their consenting customers via electronic media. (62 Federal Register 39,104 (July 22, 1997).)

• Rule amendments to eliminate Commission-mandated risk disclosure for certain categories of financially sophisticated customers. (63 Federal Register 8,566 (February 20, 1998).)

• Rules establishing a pilot program to lift the ban on the trading of agricultural trade options. (63 Federal Register 18,821 (April 16, 1998).)

• Approval of innovative exchange programs such as NYMEX�s market maker program (63 Federal Register 27,058 (May 15, 1998)) and NYMEX's proposed exchange of futures for swaps. (Commission Order, January 7, 1999).

• Rules to eliminate the short option value charge against the capital of FCMs. (63 Federal Register 32,725 (June 16, 1998).)

• Rules to permit futures-style margining of commodity options. (63 Federal Register 32,726 (June 16, 1998).)

• Rule amendments granting increased flexibility concerning exchange trading hours. (63 Federal Register 33,848 (June 22, 1998).)

• Proposed rules to streamline further the contract market designation process under Commission Guideline 1. (63 Federal Register 38,537 (July 17, 1998).)

• Rule amendments to permit post-execution allocation of bunched orders of sophisticated customers of a CTA or investment advisor. (63 Federal Register 45,699 (August 27, 1998).)

• Rule amendments to modernize the Commission�s rules relating to procedures for administrative enforcement proceedings. (63 Federal Register 55,784 (October 19, 1998).)

• Rule amendments allowing two-part disclosure by CPOs to customers. (63 Federal Register 58,300 (October 30, 1998).)

• Rule amendments establishing a streamlined procedure for firms or persons seeking no-action determinations, exemptions and interpretations from the Commission�s staff. (63 Federal Register 68,175 (December 10, 1998).)

• Rule amendments to ease the Commission�s speculative limit rules. (64 Federal Register (May 5, 1999).)

• Rule amendments to change the Commission�s recordkeeping requirements to permit expanded use of electronic storage media. (64 Federal Register 28,735 (May 27, 1999).)

• Rule amendments regarding registration, exemption and disclosure by introducing brokers ("IBs"), CPOs and CTAs trading foreign futures and option contracts on behalf of U.S. clients and pool participants. (64 Federal Register 28,910 (May 28, 1999).)

• Advisory on alternative execution procedures, or block trading, for the futures industry. (64 Federal Register 31,195 (June 10, 1999).)

• Proposed rule amendments to streamline the contract market rule review and approval procedures for terms and conditions. (64 Federal Register 38,159 (July 15, 1999).)

• Advisories on alternative methods of compliance with requirements for disclosure of exchange disciplinary information and access denial actions. (64 Federal Register 39,912 and 39,915 (July 23, 1999).)

• Proposed rule amendments to establish a pilot program to permit the listing of futures and option contracts on U.S. exchanges prior to CFTC review and approval. (64 Federal Register 40,528 (July 27, 1999).)

• Proposed rule amendments to provide a uniform method for computation, documentation and disclosure of the past performance of trading programs offered to the public by CTAs. (64 Federal Register 41,843 (August 2, 1999).)

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