MFA Submits Regulatory Priorities Letter to SEC

On Thursday, May 18, MFA sent SEC Chairman Jay Clayton a letter welcoming him to his new position and discussing some of MFA’s regulatory agenda priorities.  In the letter, we express support for efforts to modernize and simplify the regulatory framework for capital markets and asset managers towards the goals of enhancing investment activity, capital formation and economic growth.  The letter explains that these goals can be achieved through a sensible approach to regulatory modernization that protects investors, enhances regulatory coordination, promotes market transparency and increases market fairness and efficiency.

The letter includes SEC-related priority issues across MFA’s substantive policy committees. Specifically, the topics and recommendations in the letter include the following:

  • Ensure Data Security and Treatment of Confidential Information
  • Systemic Risk Regulation
  • Consolidate Private Fund Systemic Risk Reporting Forms Into a Single Form and Simplify the Information on the Form
  • Simplify SEC and CFTC Registration for Private Fund Managers
  • Hart-Scott-Rodino Investment-Only Exemption
  • Stress Test Requirements For Non-Bank Entities
  • Maintain SEC Examinations of SEC-Registered Investment Advisers to Private Funds
  • Amend Proposed Rule 18-4(d)(2) to Clarify the Application of Required Subordination of Segregated Customer Margin for Uncleared Security-Based Swaps
  • Ensure that Equity Market Structure Reforms Serve the Needs of Investors
  • Update Rule 105 of Regulation M under the Exchange Act
  • Modernize the Advisers Act Advertising Rules
  • Update Rule 102 of Regulation M under the Exchange Act
  • Adopt an Amendment to the SEC Rules of Practice Requiring the Automatic Withdrawal of Long-Delayed Rule Proposals
  • Adopt the Proposed Rule Permitting Additional Investments by Investment Companies and Private Funds in ETFs
  • Maintain Objective Standards in the Definition of Accredited Investor
  • Expand the Definition of “Knowledgeable Employee”