Comment Letter on Investment Adviser Performance Compensation Proposal

MFA submitted a comment letter to the SEC in response to its proposal to increase the qualification thresholds for investors in certain private funds, in accordance with the Dodd-Frank Act. In our letter, we express support for increasing the net worth and assets under management standards in the definition of qualified client in the Advisers Act to ensure that private funds are sold only to sophisticated investors. We also support the proposal to apply the rule on a prospective basis in order to avoid unnecessarily disrupting an investment advisers existing contractual arrangements.

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