MFA Comment Letters

Topic: abusive practices

MFA Submits Comments on Hong Kong Consultation on Electronic Trading09.23.12


On September 23, MFA submitted comments to the Hong Kong Securities and Futures Commission on its consultation paper on the […]

MFA Submits Letter to IRS on Proposed Rules on Dividend Equivalent Payments04.06.12


MFA submitted a comment letter to the Internal Revenue Service on the IRS proposed rules under Section 871(m) of the […]

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Topics: Internal Revenue Service IRS, dividend equivalent, tax avoidance, market participants, contractual representations, undue market disruption, swaps, delta-one instruments, customized index, derivatives, equity linked derivatives markets, in connection with standard, in the market, crossing transactions, short-term trades, high-frequency trading, gross witholding, cascading witholding taxes, special dividends, witholding agent, FATCA, specified notional principal contracts, SNPC, outstanding positions, dividend equivalent payments, abusive practices, non-U.S. persons, out-of-the-money, equity-linked swaps, options, futures, underlying security, strike price, dividend payment, dividend swaps, long-party, short-party, future dividend flow, anti-abuse rule, delta-one, International Swaps and Dealers Association, ISDA, delta, delta one instrument, non-delta one instrument, 90-Day Rule, retested, market forces, broad-based indices, market sector, credit, leverage, trading strategies, recognized independent index publisher, options contracts, proprietary index, preferred stock, common stock, illiquid securities, derivatives transactions, private funds, public float, hedge, synthetic exposure, offsetting position, individual trade determinations, investment algorithms, compliance restrictions, long equity swap, investment fund, single strategy fund, multi-strategy fund, average daily trading volume, ADTV, public float test, Bloomberg, direct or indirect "cross", crossing, full notional amount, internal tax review system, real-time identification of offsetting positions, 30 day liquidity, Department of the Treasury, overwitholding, extraordinary dividend, Options Clearing Corporation, OCC, ordinary divident, special dividend, OTC option, options market,

MFA Response to CESR Consultation Paper on a Proposal for a Pan-European Short Selling Disclosure Regime10.01.09


MFA submitted a letter to the Committee of European Securities Regulators (CESR) today in response to its Consultation Paper on a […]

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Topics: Committee of European Securities Regulators CESR, CESR Proposal for a Pan-European Short Selling Disclosure Regime, alternative investment managers, hedge funds, fund of funds, hybrid funds, 130/30 funds, managed futures funds, industry service providers, alternative investment industry, absolute return strategies, short selling, manipulative conduct, Market Confidence, stability, public disclosure of short positions, short positions, market volatility, price discovery, risk management, risk management function, significant adverse effect, financial services sector, investors, Issuer, market participants, de minimis, aggregated anonymised data, timeframe for reporting, transparency directive, meaningful data, short selling bans, global equity markets, academics, liquidity, bid-ask spread, price declines, materially negative impacts, market efficiency, short selling disclosure regime, equity markets, enhanced transparency, investment managers, abusive short selling practices, abusive practices, financial institutions, herding, institutional investors, retail investors, transaction costs, capital markets, free flow of information, chilling effect, alternative investment classes, Pension Funds, endowments, foundations, alternative investment vehicles, hedging strategies, capital formation, hedge, convertible arbitrage, short equity position, convertible bonds, traditional bond issuance, convertible securities, short squeeze, Reverse Engineered, trading strategies, long equity positions, exposures, Unwind, financial stocks, pricing efficiency, short selling prohibitions, European markets, large-scale short selling, extreme market conditions, negative returns, UK Financial Services Authority, FSA, securities prices, naked short selling, Journal of Finance, Credit Suisse, market stability, disclosure thresholds, private reporting, flagging short sales, Financial Regulatory Authority, FINRA, flagging regime, disproportionate costs, real time information, over-the-counter transactions, exchanges, trading platform, settlement, physical short sales transactions, EEA stock, extraterritoriality, European Union, EU, EEA equities, two-tier disclosure model, price amplification, market testing, MiFID, competent authorities, Member State competent authorities, professional secrecy, confidentiality, freedom of information regimes, harmonization, net economic short positions, transitory short position, abusive behavior, share issues, capital raising, index trading, basket trade, reporting regimes, net economic short position, asset management company, aggregation, prudential regulators, T+1 reporting, derivatives, derivative positions, delta adjusted, cumulative compliance costs, global capital markets, EU Member State, market maker, market making,
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