MFA Submits Joint Comment Letter to CFTC on Netting of Uncleared Swaps for 4.5 and 4.13(a)(3)

MFA jointly submitted with the Investment Company Institute, Investment Adviser Association and the Asset Manager’s Group of SIFMA a letter to Gary Barnett, Director of the Division of Swap Dealer and Intermediary Oversight, CFTC.  The associations request that the Division grant relief to permit sponsors of registered investment companies and privately offered investment funds to net certain uncleared swaps held by a fund when applying the net notional test in amended Regulation 4.5 or 4.13(a)(3).  Specifically, the associations request that a fund be permitted to net uncleared swaps for purposes of the net notional test provided that: (1) the termination dates of offsetting swaps are the same; and (2) the reference asset or rate for the offsetting swaps is the same.