MFA filed comments to the U.S. Trustee in response to its proposed guidelines for reviewing applications for compensation & reimbursement of expenses filed under 11 U.S.C. § 330 by attorneys in larger chapter 11 cases. MFA believes that additional disclosures are necessary to assure that compensation applicants are satisfying the statutory burden to demonstrate that compensation is reasonable based on comparable services. In particular, disclosures should address “effective” rates—what professionals actually charge and collect, including alternative fee arrangements.