MFA Files Joint Letter to CFTC Requesting a Time Extension for Compliance with Amendments Regarding Section 4.13

MFA, IAA, and AIMA filed a letter requesting the CFTC grant an extension in time for compliance with the amendments regarding section 4.13.

In our letter, we request that the CFTC:

  1. Extend the period by which a CPO may still claim an exemption pursuant to section 4.13(a)(4) with respect to a newly formed pool from April 24, 2012 to December 31, 2012; and
  2. Extend the date by which a CPO can claim exemption under section 4.13(a)(3) without taking into account any swaps traded on behalf of the pool from the later of December 31, 2012 or 60 days after the effective date of the final rulemaking further defining “swap” and establishing margin requirements for swaps to 10 months from the publication of final rules on the definition of swaps and margin requirements for swaps.