Managed Funds Association

MFA submitted a comment letter to the CFTC on "Reporting, Recordkeeping, and Daily Trading Records Requirements for Swap Dealers and Major Swap Participants." MFA recommended that the CFTC make careful and appropriate distinctions between the requirements for swap dealers ("SDs") and those for major swap participants ("MSPs") to reflect the fundamental differences in their businesses, structures and characteristics. In particular, MFA requested that the CFTC make certain changes to the proposed rule so that MSPs are not generally required to maintain certain records and information that are only appropriate for, and customarily maintained by, SDs because of their market making activities.