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MFA Submits Comment Letter in Response to SEC Proposed Rule to Shorten the Settlement Cycle to T+1

MFA submitted a comment letter to the Securities and Exchange Commission (SEC) in response to its proposed rule to shorten the settlement cycle to T+1. In the letter, MFA shares support for the Commission’s proposal, which is consistent with MFA’s recently released market structure recommendations. MFA calls on the Commission to:

  • Delay the proposed compliance date of March 31, 2024, until no earlier than September 3, 2024, the Tuesday following Labor Day weekend, and, in any case, should land on the Tuesday following a holiday weekend.
  • Modify rule 15c6-1 to exempt, or further exemptive relief should be provided for, security-based swaps.
  • Evaluate market participants’ experiences with the transition to T+1 and, thereafter, engage the public for comment on a transition to T+0.