MFA submitted a letter to the Securities and Exchange Commission (SEC) in response to proposed amendments to Rule 15c2-11.
MFA requests that the Commission consider the following observations and recommendations:
- The focus of Rule 15c2-11 is the retail OTC equity markets, which operate very differently than fixed income markets.
- Extending Rule 15c2-11 beyond equity markets would reduce liquidity and transparency.
- Limiting Rule 15c2-11 to equity securities aligns with statutory purpose and investor protection.
- The definition of “equity security” in Rule 3a11-1 is overly-broad for purposes of Rule 15c2-11.
