MFA Comment Letter on SEC Proposed Liquidity Risk Management Rules

On January 13, MFA submitted a comment letter in response to the SEC’s proposed liquidity risk management rules for registered investment companies.  In our letter, MFA: (1) expressed general support for the activities-based approach taken by the SEC to address regulatory concerns about liquidity risk; (2) supported the SEC’s proposed exclusion of private funds from the scope of the rule; and (3) encouraged the SEC to adopt a final rule that provides registered investment companies and their managers with appropriate flexibility in establishing and implementing liquidity risk management programs, to avoid potential unintended consequences from a one-size fits all approach.