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8.9.2010
MFA submitted a letter to the SEC on its Consolidated Audit Trail Proposal. MFA fully supports regulators having efficient access to appropriate granular information. MFA members make significant investments in market research, proprietary investment technology and intellectual property, and the confidentiality of such information is critical to the success of their businesses. As such, MFA has a strong interest in ensuring that the Consolidated Audit Trail Proposal adequately protects intellectual property of market participants and submit comments to the Commission in this respect.
7.9.2010
MFA submitted a comment letter in response to the European Commission’s (EC) Consultation Paper on Derivatives and Market Infrastructures. In our letter, MFA expressed our general support of the bottom-up approach to the EC’s mandatory clearing obligation, the general approach specified in the consultation on organizational requirements and governance processes for European central counterparties, as well as other aspects of the consultation.
7.9.2010
MFA submitted a letter to the European Commission in response to its Consultation Paper on Short Selling. In our letter, we recommend that any rules: (i) require private, confidential reporting to a regulator at a de minimis threshold of at least 0.5%; and (ii) prohibit naked short selling when the investor has neither pre-borrowed, agreed to borrow, nor has reasonable grounds that it will be able to borrow the shares by the time of settlement.
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