Comment Letter to SEC Responding to Proposed Rule Regarding Risk Management Controls for Broker-Dealers with Market Access

March 29, 2010

From: MFA, Stuart Kaswell


Elizabeth Murphy, SEC
Mary Schapiro, Kathleen Casey, Elisse Walter, Luis Aguilar, Troy Paredes, Robert Cook, James Brigagliano

MFA submitted comments to the SEC in response to its request for comments on its proposed rule on Risk Management Controls for Brokers or Dealers with Market Access. MFA supports the SECs proposal to require broker-dealers to apply appropriate and pragmatic market access risk management controls for both proprietary and customer order flow, but believes that a final rule should be constructed to permit some flexibility in the implementation of the controls. We also believe it is appropriate for the SEC in an adopting release to reiterate the need for broker-dealers to maintain confidentiality safeguards to prevent the misuse of a customers order information.