Comment Letter on Proposals Responding to Events of May 6, 2010

MFA submitted a letter and appendix to the SEC-CFTC Joint Advisory Committee on Emerging Regulatory Issues commenting on the market events of May 6, 2010 and related market structure issues. MFA generally supports banning stub quotes, implementing uniform market-wide single stock circuit breakers and clearly erroneous trade rules, and expanding the bandwidth for market data to ensure timely quotations. However, we are concerned that proposals that impose market maker obligations on non-market makers or minimum order durations could lead to fewer buyers and sellers competing to provide better prices, which would result in less liquidity and higher transaction costs for all investors. In our letter, we urge regulators to collect and weigh empirical data before proceeding with further changes to market structure.