MFA Submits Comments to Regulators on Proposed Volcker Rule

MFA submitted a comment letter to the SEC, CFTC, and the banking agencies in response to the agencies proposed Volcker Rule. In our letter, we encouraged the agencies to implement the Volcker Rule in a way that does not impede two important intermediary functions of banks and broker-dealers, i.e., market making functions in various assets and markets and distribution platforms for customers to invest in third-party private investment funds. We further encouraged the agencies to alter the proposed rules to ensure that the presence of U.S. residents in an offshore fund managed by a U.S. non-banking entity does not prevent foreign banks from investing in that fund.