MFA on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants

MFA Comment Letter

RIN 3038-AC96

February 28, 2011

MFA submitted a comment letter to the CFTC on its proposal on "Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants." MFA asked the CFTC to further consider the implications of its proposed confirmation timing requirements and clarify the requirement to process transactions electronically. It also recommended that the CFTC require position level portfolio reconciliation only for market participants that do not regularly exchange collateral on their derivatives exposure and only upon the occurrence of a material margin dispute. Lastly, MFA asked the CFTC to reconsider imposition of portfolio compression requirements because we believe they are appropriate only for entities with swap portfolios large enough for a compression exercise to yield meaningful benefits that justify the substantial cost.

Cross References

Dodd-Frank Act, Title VII, Sec. 731; 17 CFR Part 23