Comment Letter to FINRA in Response to its Notice-to Members 11-04 on Proposed Amendments to FINRA Rule 5122 on Private Placements of Securities

MFA submitted comments to FINRA in response to its Notice-to Members 11-04 on proposed amendments to FINRA Rule 5122 on private placements of securities. MFA does not believe it is necessary for FINRA to regulate the substance of privately offered commodity pools and investment funds. In our letter, we recommend that the proposed rule exempt offerings sold pursuant to Sections 3(c)(7) of the Investment Company Act and offerings sold pursuant to Section 3(c)(1) of the Investment Company Act where the adviser is registered with the SEC or CFTC/NFA.

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