MFA Submits Comment Letter to the SEC & CFTC in Response to its Proposed Amendments to Form PF

On October 11, MFA submitted a comment letter to the U.S. Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC) in response to its proposed amendments to Form PF. The letter emphasizes that the comment period was far too short for MFA to provide adequate comments to the SEC and that, as a result, MFA will submit its full comments in the coming weeks.

In the letter, MFA points out that its request to the SEC and CFTC—cosigned by eight other associations—asking for a 60-day extension to the comment period was not granted. Further highlights from the letter are available below.

MFA highlights that they did not want to provide incomplete comments given the potential impact of the proposal. From the letter:

“This rule will have far-reaching consequences for our industry, and MFA does not want to provide partial or unexplained responses when with a few weeks more we can submit a much more useful response to the Commissions. As such, MFA is unable to submit comments by today’s deadline.”

MFA emphasizes that the comment period was too brief to enable MFA and its members to fully assess the impact of the proposal. From the letter:

“The comment period was too brief for MFA and its members to appropriately analyze the changes to Form PF, understand their full scope and implications, and collect, analyze, and present the detailed information and comments that the Commissions need.”

MFA shares that they will submit a comment letter in the coming weeks and work with the SEC to enhance the proposal. From the letter:

“MFA will continue to work on its comments and plans to submit them to the Commissions in the coming weeks. MFA appreciates the importance of collecting useful and informative data to regulators and looks forward to working with the Commissions and their staffs on enhancing the usefulness of the current Form PF in the most practical and least burdensome way.”