Comment Letter in Response to the Board of Governors of the Federal Reserve Systems Proposed Rules to Define Certain Terms in Title I of the Dodd-Frank Act

MFA filed a comment letter in response to the Board of Governors of the Federal Reserve Systems proposed rules to define certain terms in Title I of the Dodd-Frank Act, including the term significant non-bank financial company. In our letter, we encourage the Federal Reserve: (i) to exclude assets under management from the calculation of an investment advisers assets for purposes of the $50 billion threshold, regardless of the accounting treatment of those assets under management; (ii) not to require investment funds to consolidate their assets for purposes of the threshold solely because the funds are managed by the same adviser; (iii) to index the threshold to account for inflation and the growth of capital markets; and (iv) not to publish a list of firms that meet the threshold. We also expressed support for the proposed definition of when a company is predominantly engaged in financial activities.

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