MFA Comment Letters

Topic: alternative investment funds

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: CFTC Commodity Futures Trading Commission, Timothy Massad, Mark Wetjen, Scott O'Malia, Sharon Bowen, J. Christopher Giancarlo, swaps, commodity pool operators, CPO, commodity trading advisors, CTA, alternative investment strategies, Dodd-Frank Act, OTC derivatives, systemic risk, transparency, central clearing, swap execution facilities, SEF, designated contract markets, DCM, regulation, package transactions, market infrastructures, recordkeeping requirements, swap data reporting, Cross-Border, central counterparties, CCP, third country, regulatory requirements, alternative investment funds, EMIR, JOBS Act, private investment vehicles, regulatory framework, hedge fund, fund of funds, private equity fund, real estate investment trust, burdensome, CPO delegation, temporary interim relief, private funds, harmonization, no-action relief, SEC, Securities and Exchange Commission, Policy Makers, customer protection, U.S. Congress, Bankruptcy Code, futures commission merchant, FCM, legal segregation with operation commingling, LSOC, market participant, MF Global Inc., Peregrine Financial Group, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, segregated account, FCM counterparty, position limits, buy-side, straight-through processing, made available for trading, MAT, inter-dealer market, anonymity, execution, proprietary trading tools, dealer-to-customer platforms, liquidity, derivatives clearing organization, DCO, Dealer, interest rate markets, swap curves, swap butterflies, invoice spreads, swaptions, Vincent A. McGonagle, exchange for related position, EFRPs, benchmark contracts, SIFMA AMG, Asset Management Group of the Securities Industry and Financial Markets Association, Division of Swap Dealer and Intermediary Oversight, Division of Market Oversight, introducing broker, assets under management, AUM, trading privileges, commodity pool, floor brokers, Alternative Investment Management Association, AIMA, swap data repository, SDR, Commodity Markets Council, alpha swap, beta swap, gamma swap, Major Swap Participant, MSPs, European Union, EU, bespoke swaps, International Swaps and Derivatives Association, ISDA, master agreement, European Commission, OTC Derivatives Regulators Group, mandatory clearing, United States, Cayman Islands, U.S. person, swap dealer, financial counterparty, commodity interests, privately offered commodity pools, Cayman Islands Monetary Authority, British Virgin Islands Financial Services Commission, Financial Conduct Authority, Hong Kong, Securities and Futures Commission, private investment funds, limited partnership, general partner, corporations, Trust, limited liability companies, public investment fund, board of directors, chilling effect, NFA, National Futures Association, due diligence, compliance, registered investment adviser, President Obama, Obama Administration, U.S. Department of the Treasury, quarterly account statements, service providers, illiquid assets, Form PF, Form CPO-PQR, Form CTA-PR, custody rules, generally accepted accounting principles, GAAP, Form PQR, haircuts, Committee of Payment and Settlement Systems, International Organization of Securities Commissions, IOSCO, Financial Stability Board, FSB, risk management, initial margin, variation margin, loss allocation, Full Physical Segregation, customer collateral, collateral, insolvency, cleared swaps, hedgers, short, price discovery, spot-month position limits, physically settled, cash-settled contracts, natural gas, gold, silver, owned entities, passive ownership, exemptive relief, speculation, aggregation,

MFA Letter to ESAs on EMIR Risk Mitigation Regulatory Technical Standards07.14.14


MFA submitted a comment letter to the European Supervisory Authorities (ESAs) on their joint consultation paper on “Draft regulatory technical […]

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Topics: European Banking Authority European Insurance and Occupational Pension Authority, European Securities and Markets Authority, ESMA, European Supervisory Authorities, consultation paper, EMIR, European Market Infrastructure Regulation, systemic risk, counterparty credit risk, collateral, OTC derivatives market, market participants, regulatory technical standards, margin, segregation, third country, financial counterparties, non-financial counterparty, clearing threshold, variation margin, initial margin, transparency, G7, harmonization, uncleared derivative, regulatory arbitrage, Basel Committee for Banking Supervision, International Organization of Securities Commissions, IOSCO, Canada, France, Germany, Italy, Japan, United States, United Kingdom, European Commission, duplicative regulation, substituted compliance, equivalence, Cayman Islands, alternative investment funds, AIMA, Alternative Investment Management Association, European Parliament, Council of the European Union, counterparties, mandatory margin requirements, documentation, regulatory requirements, minimum notional threshold, trade repositories, settlement period, netting, trading costs, efficiency, legal opinion, verification requirement, concentration limits, proportionality principle, US Treasuries, securities, liquidity, haircuts, settlement currency, collateral currency, base currency, third party custodian, liquidation, in-scope entity, International Swaps and Derivatives Association, ISDA, dispute resolution procedures, Individual Segregation,

MFA Responds to ECON’s MiFID Questionnaire01.13.12


MFA submitted responses to MEP Markus Ferbers Questionnaire on MiFID/MiFAR 2, which asks for further information on certain aspects of […]

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Topics: Economic and Monetary Affairs Committee ECON, European Parliament, Questionnaire on MiFID/MiFIR 2 by Markus Ferber MEP, Markus Ferber, Markets in Financial Instruments Directive, eligible counterparties, custody, safekeeping, MiFID passport, professional clients, retail clients, equivalence, reciprocal access, regulatory capital, corporate governance rules, Securities and Exchange Commission, SEC, European Commission, management bodies, trading venues, corporate governance, broker crossing network, derivatives trading venues, derivatives, voice brokerage systems, alternative investment managers, alternative investment funds, broker dealers, relevant counterparties, clearing obligation, EMIR, European Market Infrastructure Regulation, central limit order book, CLOB, request for quote system, RFQ, algorithmic trading, high frequency trading, market-making activities, correlating instruments, mutual funds, arbitrage trading, high frequency/low latency, liquidity, flash crash, limit up-limit down measure, counterbalancing benefits, regulatory investigation, direct electronic access, DEA, co-location services, circuit breakers, abnormal trading conditions, confidentiality requirements, organized venues, public consultation, third country trading venues, EEA venues, reciprocal recognition, third country firms, straight-through processing, real-time registration, listed futures, listed equity derivatives, energy swaps, bilateral credit agreement, bilateral execution documentation, CCP, risk caps, SME, MTF SME, non-discriminatory access to market infrastructure, pre-trade market data, position limits, alternative arrangements, commodity derivatives, position management powers, hedging transactions, conflicts of interest, structured UCITS, non-structured UCITS, financial activity, shares, depositary receipts, exchange traded funds, ETF, broker liquidity, transparency, trading obligation, confidentiality safeguards, dark pools, approved publication arragement, APA, approved reporting mechanism, ARM, consolidated tape provider, CTP, European Supervisory Authorities, ESA, non-discriminatory access, real-time clearing, UCITS IV, packaged retail investment product, PRIP, organized trading facility, OTF, sanction,

Comment Letter to Responding to ESMA’s Call for Evidence Regarding Level 2 Implementation of the Alternative Investment Fund Managers Directive01.14.11


On January 14, MFA submitted comments to the European Securities and Markets Authority (ESMA) in response to a call for […]

MFA Comments on SEC Regulatory Initiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

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Topics: Commodity Futures Trading Commission CFTC, Securities and Exchange Commission, SEC, financial regulatory system, hedge funds, financial crisis, institutional investors, OTC derivatives market, over-the-counter derivatives market, systemic risk, operational risk, transparency, capital markets, U.S. Banking Industry, Columbia University, Investment Company Institute, Federal Financial Institutions Examination Council, leverage, market discipline, investor confidence, market stability, risk capital, proprietary strategies, international coordination, financial risk, business risk, swap dealer, swap, Counterparty, market maker, futures commission merchant, FCM, futures, Major Swap Participant, msp, non-swap dealer, AIG, initial margin, variation margin, substantial position, offsetting position, clearing, central clearing, liquidity, regulatory capital requirements, creditor, depositor, Tier 1 capital, pension plans, endowments, cleared swaps, uncleared swaps, security-based swaps, collateral, non-bank MSP, Swap Execution Facility, SEF, futures market, risk management, central counterparties, CCP, risk model, customer protection, risk committee, proprietary asset, customer asset, third party custodian, segregation, omnibus account, individual account, reporting, Designated Contract Market, market integrity, physical market, position limits, contract market, commodity trading advisor, CTA, investment adviser, Peavey Commodity Futures Fund no-action letter, commodity pool operator, Financial Stability Oversight Council, FSOC, Office of Financial Research, owned funds, residual value, managed funds, investment portfolio, roll-over, commercial paper, credit exposure, Federal Deposit Insurance Corporation, FDIC, Troubled Asset Relief Program, TARP, Federal Reserve, "too big to fail, bankruptcy law, Bondholder, private investment funds, mutual fund, client, pooled vehicle, pooled investment vehicle, Investor Protection, self-regulatory organization, SRO, investment adviser examination, Comptroller General of the United States, capital formation, Office of Compliance Inspections and Examinations, OCIE, private funds, global banks, retail clients, proprietary information, Confidential Information, Venture Capital Fund, family office, accredited investor, qualified client, knowledgeable employees, transitional relief, performance reports, market makers, Broker, fiduciary, Major Security-Based Swap Participant, MSSP, registration, margin requirement, risk profile, financial entities, Price Manipulation, executive compensation, many-to-many platform, covered financial institution, Incentive-Based Compensation Arrangements, Regulation D, disqalifying felons, Bad Actors, CUSIP number, short selling, Disclosure, price discovery, volatility, retail funds, global market, equity market, herding, Form SH, beneficial ownership, short swing profit reporting, fiduciary standard, Investor Advisory Committee, European Commission, EC, European Union, EU, European Parliament, EP, European Council of Finance Ministers, alternative investment funds, AIFs, SEC-registered advisers, Secretary Geithner, European Commissioner Michel Barnier, U.K. Chancellor of the Exchequer Alistair Darling, non-bank financial companies,