MFA submitted a comment letter to the Commodity Futures Trading Commission (CFTC) in response to the National Futures Association’s (NFA) Proposed Interpretive Notice 9083 entitled Compliance Rules 2-9(a) and (d), 2-36(e) and 2-51(d): Member Supervisory Obligations for Associated Persons.
The letter states that the CFTC should immediately institute a review of the Proposed Interpretive Notice. The NFA Staff failed to address material concerns relating to alternative asset managers. As described in the letter, the Proposed Interpretive Notice gives rise to unreasonable new burdens, is ambiguous, and is not properly tailored to alternative asset managers. For these reasons, the Proposed Interpretive Notice is not in the public interest and the CFTC ultimately should reject it absent considerable revision.
