MFA Letter on Proposed Changes to SEC Form 13F
September 29, 2020
On September 29, MFA submitted comments in response to the SEC’s proposed rules to amend the threshold for investment managers to file Form 13F reports. In the letter, we expressed concern that the proposed rules do not fully consider the ways that market participants use Form 13F data and that the SEC should reassess its cost-benefit analysis and provide a further opportunity for public review and comment of a revised cost-benefit analysis through a re-proposal, if the Commission decides to move forward with a revised reporting threshold. We also encouraged the Commission, if it decides to move forward with rulemaking: (1) not to remove the option for managers to exclude de minimis positions; (2) adopt the proposed technical changes to filings; and (3) maintain the existing standards to request confidential treatment or, at a minimum, provide guidance on how managers can meet the new standards proposed by the Commission.