MFA submitted a comment letter to the SEC in response to its Sequencing Roadmap Policy Statement on the compliance dates for final Title VII rules applicable to security-based swaps (“SB swaps”). In the letter, MFA recommended that:
(i) rules that are not interdependent should be finalized expeditiously in parallel;
(ii) mandatory clearing rules should be elevated to the second category to work concurrently with SB swap reporting rules;
(iii) the SEC should rapidly advance its proposed customer protection regime and its approval of petitions for portfolio margining with swaps;
(iv) the SEC should adopt a rule requiring the straight-through-processing of cleared SB swap transactions as an additional prerequisite to mandatory clearing;
(v) the SEC should adopt a 90-day compliance period for mandatory clearing of single-name credit default swaps for all market participants;
(vi) the SEC should sequence mandatory trade execution compliance after mandatory clearing; and
(vii) the SEC should not phase in margining requirements for uncleared SB swaps by type of SB swap market participant.