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Posting date  
2.12.2010MFA submitted a letter to Treasury Deputy Secretary Neal Wolin, which set out several issues related to the treatment of OTC derivatives contracts in the context of bankruptcy and resolution authority. Specifically, the letter set out concerns regarding the segregation of collateral and portability of OTC contracts in the event that a clearing member of a central counterparty provider goes into bankruptcy. The letter summarized the analysis and proposed legislative amendments with respect to the U.S. central clearing proposals that are contained in a report prepared last year by Cleary Gottlieb Steen & Hamilton. The letter also set out differences in the treatment of derivatives contracts under the Bankruptcy Code and the Resolution Authority title passed by the House of Representatives, respectively.
2.5.2010MFA submitted comments to the U.S. GAO in response to its request for comments on the Joint Report of the SEC and CFTC on Harmonization of Regulation”.  In our letter we discuss recommendations we support, such as aligning specific private fund reporting requirements, creating a joint information technology task force, facilitating portfolio margining, and creating a process that would facilitate the product approval process and provide legal certainty.  We also discuss concerns with recommendations and areas that the Joint Report does not cover.
 
 
 
 
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