MFA Comment Letters

Topic: Board of Governors of the Federal Reserve System

MFA Submits Letter and White Paper on Protection of Non-Public, Sensitive, and Proprietary Information by FSOC Members05.22.13


MFA submitted a cover letter and white paper to each member of the Financial Stability Oversight Council (FSOC) on the […]

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Topics: FSOC Financial Stability Oversight Council, market structure, SEC, CFTC, CTA, CPO, Securities and Exchange Commission, Commodity Futures Trading Commission, Dodd-Frank Act, market participants, financial stability, Managed Funds Association, Department of the Treasury, Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, FDIC, Federal Housing Finance Agency, National Credit Union Administration, Office of Financial Research, Federal Insurance Office, data collection, research, trade sectrets, liquidation, investment advisers, Richard H. Baker, U.S. House of Representatives Committee on Financial Services, data repositories, Trading Activities, harmonization, U.S. securities law, commodity pool operator, commodity trading advisor, self-regulatory organization, SRO, intermediary, broker-dealer, futures commission merchants, FCM, swap data repository, SDR, clearinghouses, systemic risk, Form PF, Form CPO-PQR, Form CTA-PR, registered investment adviser, adviser registration, substituted compliance, confidentiality, inspector general reports, Reverse Engineered, Trade Secrets, front running, SEC Office of Inspector General, Andrei Kirilenko, Adam Clark-Joseph, Jaksa Cvitanic, high frequency trading, National Institute of Standards and Technology, NIST, reporting, President Obama, information security program, Rulemaking, Council of Inspectors General on Financial Oversight, CIGFO, Security-Based Swap Data Repositories, SBSDR, Designated Clearing Organizations, DCO, Richard A. Shilts, legal entity identifiers,

MFA Submits Accompanying Portfolio Margining Letter11.26.12


MFA submitted a supplemental comment letter to the U.S. prudential regulators during the reopened comment period for their proposed rulemaking […]

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Topics: Office of the Comptroller of the Currency Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, FDIC, Farm Credit Administration, capital requirements, margin, covered swap entities, prudential regulators, swap dealer, Major Swap Participant, Security-Based Swap Dealer, Major Security-Based Swap Participant, Dodd-Frank Act, portfolio margining, cross-margining, futures, options, swaps, security-based swaps, Commodity Futures Trading Commission, CFTC, futures commission merchant, FCM, broker-dealer, initial margin, collateral, Securities and Exchange Commission, SEC, regulatory regime, market participants, Options Clearing Corporation, Chicago mercantile exchange, New York Portfolio Clearing LLC, LCH.Clearnet Ltd., capital markets, over-the-counter derivatives, OTC derivatives, master netting agreements, affiliate-held collateral, Dealer, derivatives clearing organization, segmentation, market liquidity, liquidity, end-users, hedging, mandatory clearing, credit default swap, CDS, index CDS, redundant margin, swaptions, caps, floors, cross-currency swaps, inflation swaps, Cleared Products, risk, CME Group, CME Clearport, ICE Clear Credit, ICE Clear Europe, central counterparties, CCP, buy-side, debt obligation, systemic risk, posted margin, Collecting Futures Commission Merchant, Depositing Futures Commission Merchant, triangular setoff, uncleared swaps, bankruptcy, commodity broker, In re Lehman Brothers Holdings Inc et al, Chevron Products Co. v. SemCrude L.P., covered swap entity, eligible collateral, Federal National Mortgage Association, Federal Home Loan Mortgage Corporation, Federal Home Loan Banks, Federal Agricultural Mortgage Corporation, insured obligation, Farm Credit System,

MFA Submits Amicus Brief on Issue of Creditor Coordination06.29.12


On June 29, MFA filed an amicus brief in the 11th Circuit en banc review of the CompuCredit case.  At […]

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Topics: U.S. Court of Appeals for the Eleventh Circuit Compucredit Holdings Corporation v. Akanthos Capital Management LLC, Loan Syndications and Trading Association, Securities Industry and Financial Markets Association, SIFMA, Moses Silverman, Aidan Synnott, Daniel Crane, Financial Crisis Inquiry Commission, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, FDIC, Office of the Comptroller of the Currency, Edward Altman, Brendy Kuehne, New York University Salomon Center, Stern School of Business, John Coffee Jr., William Klein, Conrad Duberstein, Tomotaka Fujita, Marcel Kahan, corporate bonds, Michael MacKenzie, Nicole Bullock, Glenn Merrick, Ali Stoeppelwerth, banks, investment banks, broker-dealer, alternative investment industry, securities firms, capital formation, chilling effect, borrowers, distressed debt, contractual relationship, interest rates, creditor, credit squeeze, credit market, bonds, secondary loan markets, institutional lender, leverage, systemic risk, Shared National Credit Review, syndicated loan market, Bondholder, maturity date, debtor, Bankruptcy Filing, Bankruptcy Code, collective action risks, capital, primary market, risk portfolio, U.S. Court of Appeals for the Seventh Circuit, Judge Easterbrook, U.S. Court of Appeals for the Second Circuit, price-fixing, hedge funds, price competition, contract, bilateral monopoly, per se rules, par value, debt instruments, high-velocity market, low-velocity market, creditor coordination, market power, anticompetitive, competition, pre-packaged bankruptcy, Broad. Music Inc. v. Columbia Broadcasting Sys. Inc, Bus. Elecs. Corp. v. Sharp Elecs. Corp., Classic Cheesecake Co. Inc. v. JPMorgan Chase Bank NA, Falstaff Brewing Corp. v. New York Life Ins. Co., Federal Trade Commission v. Brown Shoe Co., Federal Trade Commission v. Indiana Federation of Dentists, Federal Trade Commission v. Superior Court Trial Lawyers Association, Finnegan v. Campeau Corp., United States v. Giordano, Ireland v. Craggs, Leegin Creative Leather Products Inc. v. PSKS Inc., Arizona v. Maricopa County Medical Society, Maris Distrib. Co. v. Anheuser-Busch Inc., National Collegiate Athletic Association v. Board of Regents, Northwest Wholesale Stationers Inc. v. Pacific Stationery & Printing Co., Palmyra Park Hosp. Inc. v. Phoebe Putney Memorial Hospital, Reisner v. General Motors Corp., Reiter v. Sonotone Corp., Sharon Steel Corp. v. Chase Manhattan Bank NA, Smith v. The Ferncliff, State Farm Mutual Auto. Ins. Co. v. Physicians Injury Care Center Inc., United States v. Topco Assocs Inc., Twin City Pipe Line Co. v. Harding Glass Co., Unijax Inc. v. Champion International Inc., United Airlines Inc. v. U.S. Bank NA, Volt Info. Scis. Inc. v. Board of Trs. of Leland Stanford Jr. University,

MFA Submits White Paper to European Commission on Shadow Banking06.01.12


On June 1, MFA submitted a white paper on hedge funds and shadow banking in response to the European Commission’s […]

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Topics: European Commission European Union, EU, Green Paper "Shadow Banking", shadow banking, shadow banking system, systemic risk, Background Note, Background Note "Shadow Banking: Scoping the Issues", Financial Stability Board, FSB, hedge fund industry, credit hedge funds, leverage, investor, counterparties, regulatory framework, regulatory arbitrage, financial industries, mutual funds, banks, financial market, investment strategies, asset classes, liquidity transformation, maturity transformation, risk analysis, liquidity protections, liquidity, equity investors, financial institutions, demand deposit accounts, collateral, margin, deposit-like characteristics, redemption terms, secured borrowings, direct lending, direct loan market, AIFMD, Alternative Investment Fund Managers Directive, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, originator, derivative transactions, total return swaps, secured financing, credit intermediation, non-bank financial insitutions, bank-like activities, maturity tra, G20, nonbank credit intermediation, hedge fund counterparties, broker-dealer, risk management, hidden leverage, bank-like regulation, assets under management, AUM, Securities and Exchange Commission, SEC, state securities regulators, regulatory assets under management, RAUM, U.S. Securities Laws, chief compliance officer, hedge fund managers, Form ADV, investment advisers, Form PF, Commodity Futures Trading Commission, CFTC, Financial Stability Oversight Council, FSOC, commodity futures contracts, swaps, commodity pool, commodity trading advisor, CTA, over-the-counter derivatives, OTC derivatives, central clearing, derivatives, segregation, transparency, major swap participants, swap dealers, derivatives market, Office of Financial Research, OFR, systemically important financial institution, SIFI, Board of Governors of the Federal Reserve System, the Fed, prudential regulation, Doug Elliott, Brookings Institution, absolute risk, Volcker Rule, Long Term Capital Management, "too big to fail, government insurance, market based regulations, House Financial Services Subcommittee on Financial Institutions and Consumer Credit, private equity, venture capital funds, property-casualty insurance, mutual funds management, money market funds, public company equity securities, institutional investment manager, insider trading, Department of the Treasury, Bureau of Economic Analysis, EU Member State, MiFID, Markets in Financial Instruments Directive, European Market Infrastructure Regulation, EMIR, Investment Company Institute, ICI, United Kingdom, counter-cyclical, creditor, taxpayer, sophisticated investors, instant liquidity funds, discount windows, gates, lock-up periods, side pockets, Financial Services Authority, FSA, uncollateralized loans, initial margin, variation margin, asset-backed commercial paper conduits, ABCP conduits, structured investment vehicles, SIV, Columbia University, leverage ratio, Lord Adair Turner, Hedge Fund Research, asset-backed securities, corporate bonds, government bonds, small and medium-sized enterprises, SME, leveraged loan markets, quantitative strategies, credit arbitrage strategies, fundamental credit analysis, distressed restructuring strategies, fixed income instruments, bankruptcy, private issue/Regulation D strategies, Regulation D, private investment in public equity, PIPE, relative value, pricing discrepancy, fixed income - asset backed, loans, credit cards, receivables, real estate, tangible financial commitments, fixed income - convertible arbitrage, convertible arbitrage, fixed income - corporate, corporate fixed income instrument, relative value - multi-strategies, Master Limited Partnership,

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

Comment Letter on Proposed Rules for Margin Requirements for Uncleared Swaps and Capital Requirements for Swap Dealers and Major Swap Participants07.11.11


MFA submitted a comment letter to the CFTC in response to both their notice of proposed rulemaking on Capital Requirements […]

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Topics: Commodity Futures Trading Commission CFTC, "Proposed Capital Rules, " "Proposed Margin Rules, margin, liquidity, swap markets, prudential regulator, CSE, buy-side firms, central clearing, uncleared swaps, customized transactions, unsecured counterparty credit risk, transparency, margin practices, two-way exchange of variation margin, netting, safeguards. designated clearing organization, DCO, Timothy Geithner, Gary Gensler, counterparties, trading costs, adverse pricing, funding costs, variation margin, collateral management practices, financial entities, non-cash collateral, Office of the Currency, Office of the Treasury, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Farm Credit Administration, Federal Housing Finance Agency, systemic risk, shielding assets, pension plans, university endowments, bilateral variation margin exchange, unsecured obligations, one-sided variation margin arrangements, SEC, "too big to fail, " uncollateralized swap positions, margin exchange, swap portfolio, counterparty credit quality, Hon. Ben S. Bernanke, risk management, asset classes, interest rate swaps, commodity swaps, equity swaps, referenced bond, Eurodollar futures, physically-settling forwards, repurchase agreements, security lending agreements, liened account assets, initial margin model, portfolio offsets, Alternative Method, net counterparty exposure, out-of-the-money swap, in-the-money swap, initial and variation margin transfers, futures commission merchant, asset class, multi-lateral agreements, cross-product netting agreements, non-cleared commodity options, liquidation value, paired products, trading contracts, capital planning, multiplier of 2.0, multiplier of 4.4, reference cleared swap, grid-based method, proprietary models, ten-day liquidation time horizon, five-day time horizon, segregation of customer assets, custodian, Capital Rules, capital requirements, Mr. Eric Chern, Chicago Trading Company, Joint Commission-SEC Staff Roundtable on Proposed Dealer and major Participant Definitions Under the Dodd-Frank Act, tailored products, Reporting of Capital Requirements, collateral delivery, counterparty exposure, Capital Relief for Cleared Swaps,

Comment Letters to Prudential Regulators on their Proposed Rules for Margin and Capital Requirements for Covered Swap Entities07.11.11


MFA submitted a comment letter to the Prudential Regulators in response to their notice of proposed rulemaking on Margin and […]

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Topics: Notice of Proposed Rulemaking on Margin and Capital Requirements for Covered Swap Entities Treasury, swap markets, central clearing, risk-based margin requirements, minimize risk, liquidity, swap dealers, SDs, major swap participants, covered swap participants, CSEs, uncleared swaps, delivery of margin, counterparties, operational costs, adverse pricing, robust netting arrangements, funding costs, customized transactions, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, unsecured counterparty credit risk, consistency, transparency, variation margin, Timothy Geithner, mandatory clearing requirements, central clearinghouse, clearing eligible, non-cash collateral, Gary Gensler, asset class, financial entity counterparties, bilateral exchange of variation margin, pension plans, university endowments, counterparty risk, systemic risk, "too big to fail, uncollaterized swap positions, indirect transmission, House Committee on Financial Services, Ben S. Bernanke, swap portfolio, risk management, cleared swap transactions, risk reduction tool, interest rate swaps, commodity swaps, FCM, credit default swap, referenced bond, interest rate swap, Eurodollar futures, security-based swaps, physically-settling forwards, repurchase agreements, security lending agreements, over-collateralization, futures commission merchant, liquidation value, cross-product netting agreements, multi-lateral netting agreements, non-cleared commodity options, paired products, trading contracts, proprietary models, equity swaps, call option, total return swap, illiquid security, ten-day liquidation time horizon, five-day time horizon, valuation formulas, swap documents, Capital Relief for Cleared Swaps, DCO, capital charge, derivatives clearing organizations, Office of the Comptroller of the Currency, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, Farm Credit Administration, Federal Deposit Insurance Corporation, FDIC, CFTC,

Comment Letter on CFTCs Proposed Rule Related to Requirements for Derivatives Clearing Organizations, Designated Contract Markets, and Swap Execution Facilities Regarding the Mitigation of Conflicts of Interest11.17.10


On November 17, MFA submitted a comment letter on the CFTCs proposed rule related to Requirements for Derivatives Clearing Organizations, […]