Comment Letter to Sen. Blanche Lincoln and Sen. Saxby Chambliss on Wall Street Transparency and Accountability Act of 2010

MFA submitted a letter to the leadership of the Senate Committee on Agriculture, Forestry and Nutrition regarding the Wall Street Transparency and Accountability Act of 2010, which seeks to regulate the over-the-counter derivatives market. In the letter, MFA expressed its support of the objectives of the bill, but highlighted several key concerns, including: (i) the definitions of swap dealer and major swap participant (MSP); (ii) the potential imposition of capital requirements on MSPs; (iii) the requirement that the recipient of any non-dealer swap margin payment be required to register as a futures commission merchant; and (iv) the authority of the SEC to establish position limits with respect to securities and security-based swaps.