MFA Comment: Position Limits for Derivatives

MFA Comment Letter

RIN: 3038-AD15 and 3038-AD16

March 28, 2011

MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains concerned that the CFTC's proposal is not empirically driven and that it may place a greater burden on interstate commerce by hindering the ability of futures markets to perform their fundamental price discovery, risk transfer and risk management functions. MFA is especially concerned that the proposal will result in unnecessary aggregation of independently controlled accounts, burden investors and investment managers, and potentially reduce liquidity in U.S. futures markets by diverting from the CFTC and exchanges' longstanding policy of disaggregating accounts based upon independence for purposes of determining positions.

Cross References

Dodd-Frank Act, Title VII, Sec. 737