MFA Submits Letter to CFTC on Proposed Aggregation Limits Rule

MFA submitted comments on the CFTC’s proposed rule on aggregation limits.  MFA was generally supportive of the CFTC’s disaggregation relief for entities that have ownership in other entities and provided a number of recommendations to further improve the proposal.  In the letter, MFA recommended that the Commission increase the level at which aggregation is required from 10% to 25% for an entity’s passive ownership interest in an operating company.  MFA supported the CFTC’s modified approach with respect to providing entities where passive ownership exceeds 50% of the owned entity with the opportunity to seek disaggregation relief.  MFA also recommended that the CFTC modify its proposal relating to the conditions for disaggregation relief for greater than 50% owned entities; and treat passive investments in a 4.13(a)(3) exempt pool the same as passive investments in other pools for purposes of disaggregation relief.