Comment Letter Responding to CFTC’s Proposed Internal Business Conduct Rules for Swap Dealers and Major Swap Participants

MFA submitted a comment letter to the CFTC in response to proposed internal business conduct rules for swap dealers and major swap participants. In our letter, MFA recommends that the CFTC: (i) clarify that the proposed rules do not impose any new fiduciary or supervisory duties on market participants; and (ii) establish a clear separation between research and trading departments, so that the criteria for clearing membership are objective and risk-based.