MFA Comments on Amendments to CPO and CTA Compliance Obligations
MFA Comment Letter
RIN 3038-AD30
April 12, 2011
MFA submitted comments to the CFTC on its proposed amendments to commodity pool operator (CPO) and commodity trading advisor (CTA) compliance obligations. Among other things, MFA commented on the CFTC's proposed amendments to section 4.5, arguing that they could be overly burdensome to some RICs and their sponsors. MFA proposed (a) that section 4.5 be amended only with respect to the Marketing Test, and (b) that the Commission grant disclosure document delivery and Part 4 disclosure relief to CPOs offering commodity derivatives mutual funds and traditional commodity pools. Finally, while MFA generally supports the proposal that Rule 4.7 pools be audited, it argued for the continuation of the availability of an exemption in limited circumstances.
Cross References
CFTC Rules 4.5 and 4.7