2007 Issue 1 - New York City Bar Association

R E C E N T C O M M I T T E E R E P O R T S
Family Partnership program. The letter specifically endorses ACS’s initiative
to allocate monies from its preventive services budget to underwrite
the cost of program support from the Partnership for pregnant teens in
the agency’s foster care population, and expresses hope that a collaborative
effort with ACS will enable the Nurse-Family Partnership to flourish
and expand in the New York metropolitan area.
Financial Reporting
Letter to the SEC providing comments on the proposal to develop additional
guidance for management regarding its evaluation and assessment
of internal control over financial reporting (ICFR). The letter supports
the notion of additional guidance as it would be an important part of
establishing an approach to the implementation of Section 404 of the
Sarbanes-Oxley Act, and it would produce disclosure that is more useful
to investors.
Futures and Derivatives Regulation
Letter to the North American Securities Administrators Association (NASAA)
commenting on the proposed revisions of the NASAA to the Guideline
for Commodity Pool Programs. The letter offers specific suggestions on
how to better clarify the proposals with regard to the definition of net
worth in the guidelines and the portfolio diversification.
Letter to the Commodity Futures Trading Commission commenting on
whether there are any conflicts between the criteria and relief in Advisory
18-96 and Commission Regulation 4.13 (a)(4). Electronic Filing of Part 4
Exemptions. Although most of the provisions of Advisory 18-96 have been
superseded by regulation, the letter argues that there is still a benefit in
retaining Advisory 18-96 in certain situations.
Letter to the Commodity Futures Trading Commission expressing support
for the proposal to amend the rules governing advertising by commodity
pool operators and commodity trading advisors, which would make explicit
that the commission’s advertising rules are equally applicable to
electronic media presentations and to traditional media. Though the letter
argues that this proposed change is consistent with other initiatives to
modernize the commission’s rules to reflect current technological changes
that affect the futures industry, it outlines several clarifications that would
make the rules more effective.
T H E R E C O R D
12