MFA submitted a comment letter on FICC’s proposed rule change in connection with the trade submission requirement.
The letter urges the SEC to work with FICC to further amend the proposed rules with respect to the Triennial Review Requirement, which MFA believes will increase costs and the risk of proprietary investment strategies being disclosed and create barriers to becoming a member of FICC.
MFA also highlights that CME proposed clearing rules are a better approach to ensuring compliance with the clearinghouse’s rules with respect to the trade submission requirement. The CME’s proposed rules meet the same regulatory objectives without the costly and excessive triennial review proposed by FICC.
