MFA Submits Letter to SEC on Sequencing Roadmap for Final Title VII Rules

August 13, 2012

From: MFA, Stuart Kaswell

To:

Elizabeth Murphy, SEC
Mary Schapiro, Elisse Walter, Luis Aguilar, Troy Paredes, Daniel Gallagher, SEC

MFA submitted a comment letter to the SEC in response to its Sequencing Roadmap Policy Statement on the compliance dates for final Title VII rules applicable to security-based swaps (“SB swaps”). In the letter, MFA recommended that:

(i)     rules that are not interdependent should be finalized expeditiously in parallel;

(ii)    mandatory clearing rules should be elevated to the second category to work concurrently with SB swap reporting rules;

(iii)   the SEC should rapidly advance its proposed customer protection regime and its approval of petitions for portfolio margining with swaps;

(iv)  the SEC should adopt a rule requiring the straight-through-processing of cleared SB swap transactions as an additional prerequisite to mandatory clearing;

(v)   the SEC should adopt a 90-day compliance period for mandatory clearing of single-name credit default swaps for all market participants;

(vi)  the SEC should sequence mandatory trade execution compliance after mandatory clearing; and

(vii) the SEC should not phase in margining requirements for uncleared SB swaps by type of SB swap market participant.

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