“While we support efforts to protect customers from abusive practices and protect participants from disputes (two of the CFTC’s stated purposes for the proposal), there is substantial cost involved in complying, without the certainty that benefits will be commensurate with costs of implementation,” the NGFA said.  “At the least, we urge the agency to adopt a generous timeline and flexible attitude toward implementation for futures commission merchants and introducing brokers, especially smaller firms for which short-term adoption of the proposed standards may pose a significant investment.”