Comment Text:
Managed Funds Association (MFA) submits a comment letter in response to the CFTC's proposed rulemaking to amend Rule 1.35(a) for RIN 3038-AE23, "Records of Commodity Interest and Related Cash or Forward Transactions". MFA also resubmits a related petition for rulemaking to amend Rule 1.31, originally filed with the CFTC on July 21, 2014, as an attachment to its Rule 1.35(a) comment letter.
