Letter Regarding the Proposal to Rescind Sections 4.13(a)(3), and (a)(4)

MFA submitted a supplemental letter to its April 12 letter to the CFTC on its proposal to rescind certain Private Pool Exemptions with respect to registration as a commodity pool operator. In our letter, we encourage the Commission to work with the SEC and other members of the Financial Stability Oversight Council to implement an appropriate information sharing framework for systemic risk data, and for the Commission to review and analyze Form PF data before considering whether rescission of the Private Pools Exemption is necessary. As alternatives to rescinding the Private Pool Exemptions, we propose for the Commissions consideration an information-sharing framework and a tiered registration framework, which we believe would provide the Commission with systemic risk data while minimizing unnecessary and duplicative regulation.