MFA Comment Letters

Topic: bankruptcy estate

MFA Submits Letter to SEC on Proposed Capital, Margin, and Segregation Rules02.22.13


MFA submitted a comment letter to the Securities and Exchange Commission (SEC) on its proposed rules on “Capital, Margin, and […]

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Topics: Securities and Exchange Commission SEC, margin, capital, segregation, Security-Based Swap Dealer, Major Security-Based Swap Participant, capital requirements, broker-dealer, risk, security-based swaps, customer collateral, Dodd-Frank Act, CFTC, Commodity Futures Trading Commission, Private Funds Managers, Investor Protection, regulation, international regulatory standards, efficiency, capital formation, liquidity, collateral, margin requirements, market participants, variation margin, netting, margining, Financial Industry Regulatory Authority, FINRA, international harmonization of regulations, regulatory arbitrage, federal register, bilateral exchange of variation margin, best practices, counterparty risk, systemic risk, risk management, portfolio margining, securities, cross-product master netting agreements, initial margin, financial system, asset class, counterparties, prudential regulators, leverage, derivatives, tri-party custodial arrangements, customer protection, omnibus segregation, default, fellow customer risk, legal segregation with operation commingling, LSOC, swap dealers, Major Swap Participant, Individual Segregation, buy-side firms, non-commercial end-users, hedge funds, credit risk, capital inefficiency, transparency, Basel Committee on Banking Supervision, International Organization of Securities Commissions, IOSCO, Working Group on Margining Requirements, central clearing, compliance, registered clearing agencies, mandatory clearing, compliance date, two-way margining, reform, collateral management, asymmetrical initial margin exchange, pension, endowments, university endowment, financial crisis, "too big to fail, too interconnected to fail, American International Group, AIG, House Committee on Financial Services, Ben Bernanke, Federal Reserve Board, 111th Congress, financial contagion, financial institutions, asymmetry, portfolio reconciliation, portfolio compression, Swap Trading Relationship Documentation, swap dealer, collateral management stystems, trading costs, complexity, settlement risk, credit default swap, CDS, OTC derivatives, forwards, repurchase agreements, Value at Risk, VaR, financial instrument, cross-margining, Options Clearing Corporation, Chicago Mercantile Exchange Holdings Inc., New York Portfolio Clearing LLC, LCH.Clearnet Ltd., customer replicability, proprietary information, reconciliation, market risk, haircuts, Cash Flow, pro-cyclical effects, creditworthiness, multiplier, customized risk management tools, sell-side firms, liquidation time horizon, product type, market practice, ISDA, U.S. dollar, settlement, money market instruments, eligible collateral, capital charge, Lehman Brothers, bankruptcy, bankruptcy estate, third-party custody arrangement, enhanced protections, Notice of Exclusive Control, Investment Company Institute, ICI, White Paper, Securities Industry and Financial Markets Association, SIFMA, liquidation, Federal Reserve Bank of New York, tentative net capital, dealers, Eric Chern, Chicago Trading Company, \, operational risk, Security-Based Swap Transactions, Darrell Duffie, Federal Reserve Bank of New York Staff Report No. 424, ICE Clear Europe Limited, segregation model, DCO, derivatives clearing organization, portability, insolvency, out-of-the-money, operational and legal commingling, default segregation model, MF Global Inc., Peregrine Financial Group, Fraud, investment risk, Russell Wasendorf, accounting, operational costs, Broker, Dealer, ISDA Margin Survey 2012, European Commission, European Parliament, Council of the European Union, central counterparty, CCP, trade repositories, commodity broker, Bart Chilton, Division of Clearing and Intermediary Oversight, Robert Wasserman, independent third party custodian, state bank regulator, state and federal laws,

MFA and Associations File Amicus Curiae Brief in RadLAX Gateway v. Amalgamated Bank Case Before U.S. Supreme Court03.09.12


MFA, with the Loan Syndications and Trading Association, SIFMA, and seven other trade associations submitted an amicus brief in the […]

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Topics: RadLAX Gateway Hotel LLC and RadLAX Gateway Deck LLC v Amagamated Bank write of certiorari, Mortgage Bankers Association, Securities Industry and Financial Markets Association, Loan Syndications and Trading Association, American Bankers Association, Clearing House Association, Commercial Finance Association, Equipment Leasing and Finance Association, Financial Services Roundtable, Elliot Ganz, Seth P. Waxman, Craig Goldblatt, Danielle Spinelli, Eric F. Citron, Shivaprasad Nagaraj, secured creditors, credit-bid, free-and-clear sale, secured credit, amici curiae, trade associations, corporate and commercial loans, mortgage-backed financing, asset-backed financing, private investment fund, borrowers, investment banks, manufacturers, hedge funds, funds of funds, managed futures funds, real-estate finance industry, chapter 11 plan of reorganization, collateral, undervaluation, secured financing, lien, fair and equitable, indubitable equivalent, stalking-horse bidder, Bankruptcy Code, secured creditor, cram-down, non-consenting class of secured creditors, speedy-trial deadline, statutory surplusage, consenual plans, nonconsensual free-and-clear sale, bankruptcy law, cash out, Judge Hand, clear and manifest contrary intention, Justice Brandeis, transfer, sale, sale exception, inconsequential value, valuation, present value, favored bidders, old equity, existing management, bankruptcy estate, available bidders, bidder, white knight bidders, commercial real-estate loans, commercial mortgage-backed securities, CMBS, real estate mortgage investment conduits, REMICs, BFP v. Resolution Trust Corp., Bloate v. United States, Bank of America National Trust & Savings Association v. 203 North LaSalle St. Partnership, D. Ginsberg & Sons Inc. v. Popkin, Dewsnup v. Timm, Duncan v. Walker, Dynamics Corp. of America v. CTS Corp., Easton v. German-American Bank, In re Beker Industries Corp., In re California Hancock Inc., In re FCX Inc., In re Murel Holding Corp., In re Philadelphia Newspapers LLC, In re River East Plaza LLC, In re Yale Express System Inc., Louisville Joint Stock Land Bank v. Radford, Pacific Gas & Electric Co. v. California ex rel. California Department of Toxic Substances Control, Sage v. Central Railroad Co., Toibb v. Radloff, W.B. Worthen Co. v. Kavanaugh, Wright v. Vinton Branch of Mountain Trust Bank,

Comment Letter to SEC and CFTC on Proposed Rules Defining ‘Swap,’ ‘Security-Based Swap,’ and ‘Security-Based Swap Agreement,’ and Guidance on Mixed Swaps and Security-Based Swap Agreement Recordkeeping07.22.11


MFA submitted comments to the SEC and CFTC in response to their request for comments on their proposal on the […]

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Topics: Commodity Futures Trading Commission CFTC, Securities and Exchange Commission, SEC, further definitions of swap, Security-Based Swap, security-based swap agreement, mixed swaps, security-based swap agreement recordkeeping, forward contract exclusion, commodities, 1993 energy exemption, loan participants, OTC derivatives, systemic risk, book-out contracts, market participants, nonfinancial commodity, security, deferred shipment, delivery, physically settled, physical commodity, energy commodities, oil, alternative delivery procedures, loan participations, direct or indirect ownership, beneficial ownership interest, true participation, Federal Securities Laws, netting, loan markets, participation agreements, assignment and assumption agreements, grantor, participant, Loan Syndications and Trading Association, LSTA, loan market association, LMA, lender of record, loan agreement, loan payments, true sale, bankruptcy estate, current debtor-creditor relationship, true participants, loan total return swaps, total return receiver, total return payer, reference loan, synthetic exposure, loan transfer mechanism, primary loan markets, secondary loan markets, exchange trading, central clearing, capital, margin, reporting, recordkeeping, business conduct requirements, eligible contract participants, material non-public information, private market, antifraud liabilities, loan arrangers, alternative transfer structure, syndicated loan market, institutional investors, liquidity, U.S. domiciled counterparties, non-U.S. counterparties,
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