Comment Letter to the CFTC on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants

February 28, 2011

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From: MFA, Stuart Kaswell

To:

David Stawick, CFTC
Gary Gensler, Michael Dunn, Bart Chilton, Jill Sommers, Scott O'Malia, (all) CFTC.

MFA submitted a comment letter to the CFTC on its proposal on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants. In our letter, we ask the CFTC to further consider the implications of its proposed confirmation timing requirements and clarify the requirement to process transactions electronically. Also, we respectfully recommend that the CFTC require position level portfolio reconciliation only for market participants that do not regularly exchange collateral on their derivatives exposure and only upon the occurrence of a material margin dispute. Lastly, we ask the CFTC to reconsider imposition of portfolio compression requirements because we believe they are appropriate only for entities with swap portfolios large enough for a compression exercise to yield meaningful benefits that justify the substantial cost.

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