Comment Letter to SEC and CFTC Concerning the Public Comment Process for Rules Related to the Dodd-Frank Act

MFA and several other financial services trade associations submitted a letter to the CFTC and SEC providing comments on the rulemaking process and the adoption of new rules for OTC derivatives pursuant to Dodd-Frank legislation. We commend the Commissions for their diligence and dedication with regard to the unprecedented rulemaking endeavor, but request that they reconsider the comment deadlines for rules that utilize terms that were not defined when the proposals were published. We urge the Commissions to use their discretion to propose, adopt, and implement rules in a sequence that will achieve the important goals set out by Dodd-Frank.