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MFA Submits Supplemental Comment Letter in Response to the SEC’s Private Fund Advisers Rule

On June 13, 2022, MFA submitted a second comment letter to the U.S. Securities and Exchange Commission (SEC) that re-emphasizes fundamental flaws with the proposed Private Fund Adviser rules. MFA’s letter provides further evidence of how the proposed rule will harm investors and the inadequacy of the SEC’s economic analysis. 

MFA’s comment letter highlights the unintended consequences of the rule for institutional investors—including pensions, foundations, and endowments. The letter also draws attention to the many recently proposed rules governing the private fund industry and argues that the SEC has not fully considered the aggregate impact of these rules.  

MFA issued the following statement from MFA President and CEO Bryan Corbett along with the letter 

“While we appreciate the reopening of the comment period, MFA’s further analysis of the Private Fund Adviser rules underscores the need for the SEC to withdraw its proposal. Contrary to the stated intentions of the Commission, the proposed rules would cause irreparable harm to institutional investors—including pensions, foundations, and endowments—and their ability to deliver for their beneficiaries.” 

“The proposed rules would upset the longstanding relationship between alternative asset managers and their sophisticated investors, which would ultimately raise costs, reduce transparency, and decrease investment choice for institutional investors. The alternative asset management industry plays a critical role in the portfolios of institutional investors, yet the Commission has paid little regard to the interoperability of this rule with the many other recently proposed rules governing the industry.”