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MFA Files Form PF Letter with CFTC

On October 9, MFA filed a letter with CFTC Chairman Giancarlo requesting that the CFTC and SEC streamline Form PF and reduce regulatory burdens.  This letter supplements the letter MFA recently filed with SEC Chairman Clayton. These revisions are in line with the 2017 Treasury Report on Asset Management’s recommendation that  “the SEC, the CFTC, SROs, and other regulators should work together to rationalize and harmonize the reporting regimes” in addition to Chairman Giancarlo’s Project KISS Initiative.

The letter recommends that the CFTC:

  1. Recommit to a single risk report for all CPO and adviser filers as originally intended
  2. Reduce the reporting frequency and number of monthly data points
  3. Incorporate alphanumeric identifiers to mitigate potential cyber breaches
  4. Revise certain questions to better identify potential systemic risk
  5. Simplify or eliminate certain questions that are duplicative or overly complex