MFA submitted comments on the CFTC’s proposed rule on aggregation limits. MFA was generally supportive of the CFTC’s disaggregation relief for entities that have ownership in other entities and provided a number of recommendations to further improve the proposal. In the letter, MFA recommended that the Commission increase the level at which aggregation is required from 10% to 25% for an entity’s passive ownership interest in an operating company. MFA supported the CFTC’s modified approach with respect to providing entities where passive ownership exceeds 50% of the owned entity with the opportunity to seek disaggregation relief. MFA also recommended that the CFTC modify its proposal relating to the conditions for disaggregation relief for greater than 50% owned entities; and treat passive investments in a 4.13(a)(3) exempt pool the same as passive investments in other pools for purposes of disaggregation relief.