MFA submitted a supplemental comment letter to the CFTC in response to the Commission’s notice of proposed rulemaking for Rule 4.7.
The letter makes the following additional recommendations:
- Given the proposed increase in the portfolio/asset requirements, there is no need for the Commission to implement any proposed disclosure requirements
- If the CFTC decides to move forward with any proposed disclosure requirements, it is critical that the Commission exempt CPOs and CTAs with respect to 4.7(a)(2) investors from the disclosure requirements
- The Commission should “grandfather” existing 4.7 pools that contain both 4.7(a)(2) and 4.7(a)(3) investors with respect to any minimum disclosure requirements; and
- If the Commission elects to apply disclosure requirements to 4.7(a)(3) investors, it is critical that the disclosure be principles-based and not conflict with other disclosure obligations.
