Follow-up Comment Letter on Massachusetts Directive on Trader Funds

On January 13, MFA submitted a follow-up comment letter with the Massachusetts Department of Revenue on its draft directive on professionally managed trader funds. In our letter, which we submitted in response to questions from the DoR on our November 15 comment letter, we provided additional explanations and examples about the alternative safe harbor that we proposed in our November 15 letter to the DoR. Specifically, we provided additional information regarding the proposed portfolio turnover, nature of income, and holding period tests in our proposed safe harbor.