MFA Submits Letter to CFTC Supporting Nuveen Commodities Asset Management’s Request for Interpretive Relief

MFA submitted a letter to the CFTC supporting Nuveen Commodities Asset Management’s request for interpretative relief regarding Rule 4.7(b)(1)(ii), 4.7(c)(1)(ii) and Rule 4.25(c)(3) and 4.35(b). We urged Commission staff to issue interpretative relief clarifying that: (i) Pursuant to Rule 4.7(c)(1)(ii) and notwithstanding Rule 4.25(c)(3), a CTA does not need to disclose the performance of its exempt accounts that are not related and not material to the trading program being offered in a non-exempt commodity pool; and (ii) Pursuant to Rule 4.7, a CPO of a non-exempt pool is not required to disclose a CTAs non-material exempt accounts. MFA believes the interpretative relief requested conforms with existing industry practice and is the most logical and meaningful interpretation of the rules.