MFA submitted a comment letter to the CFTC in response to its request for public comments on the portfolio margining petition submitted by ICE Clear Credit. In our letter, MFA urged the CFTC to grant the petition as soon as possible, because of the significant benefits to customers in the form of capital efficiencies and clearing access that result from portfolio margining and netting of offsetting positions in single-name credit default swaps (“Security-Based CDS”) and broad-based indices (“Index CDS”). MFA also supported ICE Clear Credit’s petition request to hold customer positions in Security-Based CDS and Index CDS, and related margin assets, in single customer omnibus accounts to implement its portfolio margining program. We noted that treatment of customer collateral posted for cleared swap positions remains subject to the CFTC’s final rule on segregation requirements for cleared swaps under Section 4d(f) of the Commodity Exchange Act. Accordingly, MFA’s comments in the letter expressing support for portfolio margining do not represent a position with respect to that rulemaking.