MBA Letter to SEC on FINRA Rule 4210

2022 Comment Letters Government Lending Policy Issue Residential
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MBA submitted comments to the Securities and Exchange Commission (SEC) regarding the margin requirements associated with Financial Industry Regulatory Authority (FINRA) Rule 4210. These proposed requirements, which have been in various stages of development and implementation for nearly a decade, would require broker-dealers to collect margin associated with the trading of agency mortgage-backed securities (MBS) on a forward-settling basis. MBA reiterated its longstanding concerns with this proposal, which has the potential to adversely impact market liquidity, hedging practices, and consumer costs.