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MFA Submits Supplemental Comment Letter to the SEC in Response to its Proposed Dealer Rule

On December 5, MFA submitted a supplemental comment letter to the U.S. Securities and Exchange Commission (SEC) in response to its proposed dealer rule.

The letter emphasizes that the Commission should not proceed with this unnecessary proposal. However, if the Commission decides to do so, it should, at the very least, revise the Proposed Rules to mitigate the damage the rule, as drafted, will cause.  MFA’s letter offers suggested changes to the Proposed Rules that generally reflect the positions set forth in our May Comment Letter and are intended to offer the Commission alternative approaches to address its policy concerns, as we understand them, while addressing some of the negative, unintended consequences of the Proposed Rules. These suggestions should not be read to imply that MFA or its members agree with the Commission’s interpretation of the Exchange Act or that the Commission has the authority to promulgate the Proposed Rules.

MFA’s letter notes that, even with the suggested changes, the Proposed Rule are unnecessary, counterproductive, and unlawful.