Comment Letter on Proposed Rulemaking for Beneficial Ownership Reporting Requirements and Security-Based Swaps; File No. S7-10-11

MFA submitted comments in support of the SECs proposal to readopt without change existing rules regarding beneficial ownership reporting requirements and to preserve the application of such rules to security-based swaps. MFA followed the legislative process leading up to the enactment of the Dodd-Frank Act closely and believe that Congress wanted to allow for the same determinations of beneficial ownership as currently exist but wanted to be explicit in its application to security-based swaps.