MFA Files Comments to CFTC on Position Limits Aggregation Proposal

MFA submitted a letter to the CFTC on it position limits Aggregation Proposal.  MFA generally supports the disaggregation relief for “owned entities” provided in the Aggregation Proposal.  MFA believes, however, that the Aggregation Proposal should be clarified to permit disaggregation in instances of commonly owned entities that share certain employees who do not control trading decisions.  MFA also believes that Commission staff should be provided with the authority to permit disaggregation on a case-by-case basis where passive ownership in the owned entity exceeds the 50 percent ownership threshold established by the Aggregation Proposal.