The National Futures Association has proposed extending its requirements that members observe “high standards of commercial honor and just and equitable principles of trade” in connection with their commodity futures activity to their swaps business too. This provision may be used by NFA as a catch-all to charge members for problematic conduct that does not precisely fit within another express prohibition (click here, for example, to see NFA Interpretive Notice 9005: “Guidelines for the Disclosure by FCMs and IBs of Costs Associated with Futures Transactions” (July 24, 2000).