MFA Submits Recommendations to CFTC for Regulatory Improvements

MFA submitted a letter congratulating Commodity Futures Trading Commission Acting Chairman Giancarlo on his nomination to serve as the next Chair of the CFTC. The letter also detailed the top regulatory matters with which the Association would like to work on with the CFTC.

The letter reiterates MFA Members’ support for smart, effective regulation of derivatives markets and the need for thoughtful, efficient regulation of hedge fund managers. MFA also applauded Acting Charmin Giancarlo’s Project KISS—Keep It Simple Stupid—initiative and the agency-wide review of CFTC regulations.

MFA’s letter discussed the following areas as ways to help the CFTC achieve its regulatory objectives while making regulation simpler, more effective and less burdensome:

  • Rationalize CPO & CTA Regulation by Reducing Redundancy with the SEC
  • Foster Economic Growth and Vibrant Financial Markets by Abandoning the Proposed CFTC Position Limits Framework
  • Adopt Regulatory Refinements to Improve CFTC Swaps Trading Framework
  • Enhance Data Security and Treatment of Confidential Information
  • Simplify Regulation of Automated Trading
  • Reduce Administrative Burden by Amending Part 4 Regulations Regarding Third-Party Recordkeeping
  • Encourage European Regulators to Resolve Equivalence Issues under EMIR Article 13 and MiFIR Article 33
  • Protect the Assets and Interests of Customers in Regulations on CCP Recovery and Resolution
  • Recalibrate and Reduce Initial Margin Requirements to Better Reflect the Actual Risk of Certain Non-Clearable Swap Products
  • Reduce Complexity of Cleared Swap Reporting Requirements by Eliminating Alpha Swap Reporting
  • Recalibrate Leverage Ratio for Cleared Derivatives to Allow Offset for Segregated Client Initial Margin