Comment Letter to the CFTC on Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties

February 22, 2011

From: MFA, Stuart Kaswell

To:

David Stawick, CFTC
Gary Gensler, Michael Dunn, Bart Chilton, Jill Sommers, Scott O'Malia, (all) CTFC.

MFA submitted a comment letter to the CFTC on its proposal on Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties. In our letter, MFA suggests that the CFTC consider separate regulatory regimes for SDs and MSPs to reflect the fundamental differences in their businesses, structures and other characteristics. We ask for clarification that the proposed rule does not impose any new fiduciary or supervisory obligations or duties on market participants. In addition, we ask for confirmation that the special entity definition and the related obligations to special entities do not apply to investment vehicles in which endowments, employee benefit plans or government entities invest.

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