The CFTC has adopted a new rule to implement a certification procedure for the offers or sales to persons located in the United States of a non-narrow-based security index futures contract traded on a foreign board of trade (Foreign Index Futures Contract). Currently, the certification procedure requires CFTC staff a no-action letter approval. However, under this new process, a foreign board of trade seeking certification for a narrow-based security index futures contract must electronically submit a formal request to the CFTC containing certain information about the specific futures contract at issue, as well as a statement that the futures contract conforms to the requirements of the CEA. The new rule also provides for an alternative, expedited certification procedure for those foreign boards of trade that have previously received either a (i) CFTC no-action letter or certification with respect to a Foreign Index Futures Contract traded on its board or a (ii) CFTC no-action letter permitting the foreign board of trade to offer U.S. traders direct access to its trading system. This rule becomes effective October 26, 2011 and can be viewed by clicking here.