MFA Submits Comment Letter Urging SEC to Evaluate Aggregate Rulemaking Costs on Investment Advisers, the Markets, and Investors

MFA submitted a comment letter to the U.S. Securities and Exchange Commission (SEC) regarding the Proposed rules that impact private fund advisers and fund investors. In the letter, MFA urges the Commission to evaluate the overall effect of its Proposals and seek less burdensome alternatives before finalizing any of its Proposed rules.   

MFA draws attention to the Commission’s omission of a comprehensive cost-benefit analysis for the Proposals when viewed collectively. Consequently, MFA expresses concerns regarding the substantial number and extensive scope of recent rulemakings by the Commission. MFA firmly believes that these actions may give rise to unintended consequences that the Commission hasn’t thoroughly considered.   

Additionally, MFA expresses apprehensions about the implementation of the Proposals, citing the substantial combined expenses and unparalleled operational and practical hurdles, especially for smaller and emerging managers. MFA raises concerns that the Commission has deprived the public of the ability to meaningfully comment on the Proposals because of their sheer number and interlocking nature.