MFA, along with FIA and SIFMA, called on the Commodity Futures Trading Commission (CFTC) to extend no-action relief for position aggregation requirements in a letter. The CFTC has granted and extended this relief since 2017, but it is set to expire in August 2025.
Aggregating positions across commonly owned or affiliated entities is complex and burdensome for asset managers. The existing relief streamlines compliance by limiting notice filings to relationships most relevant to CFTC oversight. Without it, managers would face significant operational challenges and costs tracking and reporting positions across affiliates, with little regulatory benefit.
