MFA Comments on CFTC Regulatory Intitiatives Under the Dodd-Frank Act

September 22, 2010

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Topics: Commodity Futures Trading Commission CFTC, Securities and Exchange Commission, SEC, financial regulatory system, hedge funds, financial crisis, institutional investors, OTC derivatives market, over-the-counter derivatives market, systemic risk, operational risk, transparency, capital markets, U.S. Banking Industry, Columbia University, Investment Company Institute, Federal Financial Institutions Examination Council, leverage, private investment funds, Investor Protection, market discipline, investor confidence, market stability, risk capital, proprietary strategies, international coordination, financial risk, business risk, swap dealer, swap, Counterparty, market maker, futures commission merchant, FCM, futures, Major Swap Participant, msp, non-swap dealer, AIG, initial margin, variation margin, substantial position, offsetting position, clearing, central clearing, liquidity, regulatory capital requirements, creditor, depositor, Tier 1 capital, pension plans, endowments, cleared swaps, uncleared swaps, security-based swaps, collateral, non-bank MSP, Swap Execution Facility, SEF, equity market, futures market, risk management, central counterparties, CCP, risk model, customer protection, risk committee, proprietary asset, customer asset, third party custodian, segregation, omnibus account, individual account, reporting, Designated Contract Market, market integrity, physical market, position limits, contract market, commodity trading advisor, CTA, investment adviser, Peavey Commodity Futures Fund no-action letter, commodity pool operator, Financial Stability Oversight Council, FSOC, Office of Financial Research, owned funds, residual value, managed funds, investment portfolio, roll-over, commercial paper, credit exposure, Federal Deposit Insurance Corporation, FDIC, Troubled Asset Relief Program, TARP, Federal Reserve, "too big to fail, bankruptcy law, Bondholder,
From: MFA, Richard Baker

To:

David A. Stawick, CFTC
Gary Gensler, Michael Dunn, Bart Chilton, Jill Sommers, Scott O'Malia, Dan Berkovitz, Richard Shilts, Ananda Radhakrishnan

MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank Act. MFA supports a renewed regulatory framework that will minimize systemic risk, strengthen investor protection, and promote market discipline and integrity. We recognize that the Dodd-Frank Act reframes the overall regulatory landscape, but that the SEC and the CFTC, among other agencies, will be responsible for implementing key details surrounding many of the crucial provisions. We also recognize that many of these areas are complex and new to regulatory oversight, and we pledge our support in helping the agencies address the range of issues in which our members have expertise. Please see our SEC Letter (attachment 1 and attachment 2) and our CFTC Letter for greater detail.

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