Comment Letter Responding to SEC’s Proposed Rule on the Prohibition Against Fraud, Manipulation, and Deception

MFA submitted comments to the SEC in response to its request for comments on its proposed rule on the Prohibition Against Fraud, Manipulation, and Deception in connection with Security-Based Swaps. MFA is concerned that the SEC exceeds its authority in extending the prohibitions of Rule 10b-5 and Section 17(a) of the Exchange Act to transactions between the execution and extinguishment of a security-based swap and provides the SEC with some recommendations in its letter.

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