Letter Regarding Short Sale Reporting Study Required by Dodd Frank Act Sec. 417 (a) (2); File No. 4-627

MFA submitted a letter to the SEC in response to its request for comments on its Dodd-Frank mandated study on the feasibility, benefits and costs of: (1) real-time individual short position reporting, or in the alternative real-time reporting of short positions only to regulators; and (2) conducting a voluntary pilot program in which public companies would agree to have all trades of their shares marked long, short, market maker short, buy, or buy-to-cover, and reported as such in real-time through the Consolidated Tape. MFA is concerned that the two proposals subject to SEC study would provide little benefit to the general public, but more importantly, the short-sale information gathered would be misleading to market participants. We are also concerned that the attributed short sale information would be deleterious to and perhaps intimidate investors that use short selling as part of their risk reduction techniques; useable and readily available short sale data would be extremely challenging to index; and the proposals would be costly and would directly impact our liquid and robust markets in a negative manner.

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