CFTC Staff Letter 96-58: Ethics Training Requirements for Registered APs Not Conducting Business

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U.S. COMMODITY FUTURES TRADING COMMISSION Three Lafayette Centre 1155 21st Street, NW, Washington, DC 20581 Telephone: (202) 418-5430 Facsimile: {202) 418-5536 DIVISION OF 1RADING & MARKETS Dear July 12, 1996 Re: Rule 3.34 -- Request for Clarification of Ethics Training Requirements for Registered APs Who Do Not Conduct Any Futures or Commodity Interest Business This is in response to your letter dated June 18, 1996, to the Division of Trading and Markets ("Division") of the Commodity Futures Trading Commission ("Commission"), as supplemented by telephone conversations with Division staff. You request clari￾fication of the1 ethics training requirements set forth in Commis￾sion Rule 3.34~ on behalf of twenty - two registered associated persons ("APs") employed by "X", a registered futures commission merchant and commodity trading advisor. Based upon the representations contained in your letter, as supplemented, we understand the relevant facts to be as follows. The twenty-two APs ("22 APs") do not wish to complete ethics training because they ~7 not conduct any futures or other commod￾ity interest business.- You represent that "X" has suspended the 22 APs' ability to do any business and has emphasized the importance of completing the required training . The firm would prefer that the 22 APs remain registered, without tra ding privi￾leges, until they comple te the require d training. "X" reque sts guidance on any rules or written procedures describing the actions it should take. ~/ Commission rules referred to herein are f ound at 1 7 C.F.R. Ch. I (1995), as amended by 60 Fed. Reg . 38146 (July 25, 1995). 2._/ The APs a re : "A", "B", "C", "D", "E", "F", "G", "H", " I ", "J" ' "K" ' "L" ' "M" ' II N II ' II 0 II ' "P II ' II Q" ' "R" ' II S " ' "T" ' "U" a nd "V". "K" a nd "F", 11 G", "J", "0" and "V" a r e lis t e d as b ranch managers as well.