January 16, 2015

Via Electronic Filing

The Honorable Jacob J. Lew Chairman Financial Stability Oversight Council 1500 Pennsylvania, Ave., NW Washington, DC 20220

Re: Request for Comments on Asset Management Activities and Products

Dear Secretary Lew:

Managed Funds Association (“MFA”)1 appreciates the Financial Stability Oversight Council’s (the “Council”) request for public comment on asset management activities and products. MFA plans to submit a separate substantive response to the Council’s request; however, at this time, we request that the Council extend the deadline for comments an additional 90 days.

The Council’s request for public comment raises a number of important questions that will require significant review and analysis by industry participants, including our members, in order to provide a thoughtful, comprehensive response that will assist the Council in considering these important issues. Given the breadth of issues raised by the Council and the significance of those issues to capital markets, we do not believe that the 60-day period provided in the release will provide sufficient opportunity for MFA and its members to provide the detailed response that will assist the Council in considering these issues. We also are concerned that a 60-day comment period may limit the number of market participants who are able to respond, which would limit the usefulness of the public comment period, particularly given the diverse nature of the asset management industry.

We also would like to raise with you a timing matter on a related subject -- the ongoing review by the Financial Stability Board (the “FSB”) of assessment methodologies for non-bank, non-insurer globally systemically important financial institutions (“GSIFIs”). We understand that the FSB, in conjunction with the International Organization of Securities Commissions (“IOSCO”),

1 The Managed Funds Association (MFA) represents the global alternative investment industry and its investors by advocating for sound industry practices and public policies that foster efficient, transparent, and fair capital markets. MFA, based in Washington, DC, is an advocacy, education, and communications organization established to enable hedge fund and managed futures firms in the alternative investment industry to participate in public policy discourse, share best practices and learn from peers, and communicate the industry’s contributions to the global economy. MFA members help pension plans, university endowments, charitable organizations, qualified individuals and other institutional investors to diversify their investments, manage risk, and generate attractive returns. MFA has cultivated a global membership and actively engages with regulators and policy makers in Asia, Europe, North and South America, and many other regions where MFA members are market participants.

The Honorable Jacob J. Lew January 16, 2015 Page 2 of 3 is in the process of preparing a second public consultation paper on this topic, and that the FSB- IOSCO consultation may be released early in 2015. Given the related nature of the FSB-IOSCO work with the Council’s request for public comment, we encourage Council members whose agencies are involved with the FSB-IOSCO project to encourage the FSB and IOSCO to postpone the release of their second consultation paper until after the Council has had the opportunity to review responses to its request for comment. We believe that overlapping comment periods for these related projects could create resource issues for interested parties seeking to respond, which could limit the ability of those parties to provide comprehensive responses to both requests for comment. Further, we believe that postponing the release of the FSB-IOSCO consultation will allow the responses to the Council’s request for comment to help inform the work of the FSB and IOSCO, which we believe will ultimately create a better work product for public review and comment.

Conclusion

MFA and its members welcome the opportunity to continue discussion of these important topics with the Council and we look forward to providing a thoughtful, constructive, and comprehensive response to the important topics raised by the Council in its request for comments. We believe that extending the comment period by 90 days will better ensure that the Council receives responses from a wide range of market participants that will help inform the Council as it considers these important issues. We further believe that encouraging the FSB and IOSCO to postpone the publication of their second consultation paper on assessment methodologies for non- bank, non-insurer GSIFIs will better ensure robust feedback on both requests for public comment and will allow the results of the Council’s request for comment to help inform the FSB-IOSCO project.

If the Council has any comments or questions with respect to this request, please do not hesitate to contact Benjamin Allensworth or the undersigned at +1 (202) 730-2600.

Respectfully submitted,

/s/ Stuart J. Kaswell

Stuart J. Kaswell

Executive Vice President and Managing Director, General Counsel

The Honorable Jacob J. Lew January 16, 2015 Page 3 of 3

Cc: Janet Yellen, Chair, Board of Governors of the Federal Reserve System

Martin J. Gruenberg, Chairperson, Federal Deposit Insurance Corporation

Mary Jo White, Chair, Securities and Exchange Commission

Timothy Massad, Chairman, Commodity Futures Trading Commission

Richard Cordray, Director, Consumer Financial Protection Bureau

Melvin Watt, Director, Federal Housing Finance Agency

Thomas J. Curry, Comptroller of the Currency, Office of the Comptroller of the Currency

Debbie Matz, Chairman, National Credit Union Administration

Roy Woodall, Independent Member with Insurance Expertise

Richard Berner, Director, Office of Financial Research, Department of the Treasury

Michael McRaith, Director, Federal Insurance Office, Department of the Treasury

John P. Ducrest, Commissioner, Louisiana Office of Financial Institutions

Adam Hamm , Commissioner, North Dakota Insurance Department

David Massey, Deputy Securities Administrator, North Carolina Department of the Secretary of

State, Securities Division