Managed Funds Association Views on Systemic Risk and Resolution Authority Proposals

MFA submitted this letter on behalf of MFA members to House Financial Services Committee Chairman Barney Frank (D-MA) and all other Members of the Financial Services Committee. The letter 1) provides our views regarding the “Financial Stability Improvement Act of 2009”, the systemic risk and resolution authority legislation currently being considered by the Committee; 2) expresses our significant concern with the assessment mechanism being proposed to finance the new Systemic Resolution Fund; and 3) highlights our specific objection to the recent adoption of an amendment, offered by Representative Brad Sherman (D-CA), that would ‘carve-in’ hedge funds, making them subject to the assessment at an asset threshold lower than that which would apply to other financial institutions — including those which may be systemically relevant.