Comment Letter Responding to CFTC’s Advanced Notice of Proposed Rulemaking on Antidisruptive Practices Authority

MFA submitted comments to the CFTC in response to its advanced notice of proposed rulemaking (ANPR) on Antidisruptive Practices Authority. MFA believes many of the terms referenced in the ANPR require refinement so that their meanings relate to specific and measurable characteristics that can guide market participants in their conduct and in a manner that takes into account futures and derivatives market structures, practices and customs; and submits recommendations in its letter.