MFA Comment Letters

Topic: buy-side firms

MFA and AIMA Submit Joint Letter on CPSS-IOSCO Consultative Report on Financial Market Infrastructure Recovery10.11.13


MFA and AIMA submitted a joint letter to the Committee of Payment and Settlement Systems (CPSS) and the International Organisation […]

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Topics: AIMA Alternative Investment Management Association, IOSCO, International Organization of Securities Commissions, Bank for International Settlements, Bank for International Settlements Committee on Payments, consultation paper, market infrastructures, central counterparty, CCP, clearing, exchange-traded, exchange-traded derivatives, over-the-counter derivatives, OTC derivatives, prudential regulators, mandatory clearing, collateral, clearing member, systemically important financial market infrastructure, transparency, regulatory framework, risk management, EMIR, default, Unwind, ex ante measures, orderly liquidation, haircuts, G20, variation margin, financial system, market participants, risk committees, default management committees, CFTC, Commodity Futures Trading Commission, ESMA, European Securities and Markets Authority, European Union, trading venues, liquidity, shareholders, margin, title transfer collateral arrangements, security arragements, competition, sell-side firms, systemic risk, bail-in, default waterfall, margin haircut, initial margin, bankruptcy, Dodd-Frank Act, Security-Based Swap Dealer, majory security-based swap participant, capital requirements, broker-dealer, hedge, buy-side firms, physical commodity, uncleared derivative, portfolio, mark-to-market, contagion, stress-testing methodologies, financial stability, trading volume, conflict of interest, security-based swap execution facility, security-based swap clearing agencies,

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 Submits Comment Letter in Response to Basel-IOSCO’s Consultative Document on Margin Requirements for Non-Cleared Derivatives09.28.12


MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision […]

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Topics: Basel Committee on Banking Supervision International Organization of Securities Commissions, IOSCO, margin, margin requirements, non-centrally cleared derivatives transactions, Working Group on Margining Requirements, derivatives, derivatives markets, margining, clearing, market participants, central clearing, risk management, initial margin, variation margin, best practices, liquidity, mandatory clearing, bilateral exchange, buy-side firms, segregated account, custodian accounts, hedge, hedge funds, netting, eligible collateral, portfolio margining, over-collateralization, mutually offsetting transactions, margin threshold, harmonization, uniformity, non-compliance, regulatory arbitrage, market advantage, phase-in period, implementation timeline, non-cleared derivatives, regulatory authorities, foreign exchange, swaps, forwards, risk profile, market infrastructures, liquidity characteristics, currency, Denominated in G7 Currencies, G7, cleared derivatives, systemic risk, systemic importance, systemically important, systemically important non-financial firm, liquidity costs, unlevel playing field, transparency, SIFI, systemic risk level, credit, unsecured credit extension, minimum transfer amount, MTA, prudentially regulated financial counterparties, two-way margining, standard practice, credit risk, clearing house, bilateral exchange of variation margin, market liquidity, credit default swap, CDS, novation, remaining party, party stepping out, party stepping in, novating parties, market value, Regulators, novation arrangements, liquidity mechanism, asset classes, liquidation, Dodd-Frank Act, European Union, EU, United States, ISDA, International Swaps and Derivatives Association, replacement transaction, market practices, cross-product master netting agreements, risk offsets, financial instruments, U.S. Treasury futures, Eurodollar futures, non-cleared interest rate swaps, repurchase agreements, correlated financial instruments, quantitative impact study, Portfolios, central counterparty, CCP, hedged portfolios, prudential regulators, risk characteristics, risk/reward profile, diversification, concentration limits, haircuts, segregation, third-party segregation, re-hypothecation, cost mitigation, Commodity Futures Trading Commission, CFTC, swap dealers, major swap participants, equities, delta, interest rates, CDS spreads, notional value, commodities,

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its “Proposed Interpretive Guidance […]

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Topics: CFTC Commodity Futures Trading Commission, interpretive guidance, swaps, Alternative Investment Management Association, AIMA, financial crisis, over-the-counter derivatives, OTC derivatives, OTC derivatives market, hedge fund industry, fund of funds, hedge fund managers, prime brokers, hedge fund administrator, market participants, non-U.S. market participants, regulatory requirements, commodity pool, pooled accounts, collective investment vehicles, non-U.S. investment fund, Securities and Exchange Commission, SEC, international harmonization of regulations, regulatory framework, duplicative regulation, transaction cost, compliance costs, U.S. person, non-U.S. persons, derivatives, derivatives markets, Corporation, partnership, limited liability companies, joint-stock company, fund, pension plans, estate, Trust, income tax, Jill Sommers, Scott O'Malia, cost-benefit analysis, market impact, third country, European Securities and Markets Authority, ESMA, direct or indirect ownership, Look Through, shareholders, listed entity, foreign banks, banks, dealers, commodity pool operator, CPO, Form CPO-PQR, financial stability, financial system, chief compliance officer, risk management, swap data recordkeeping, swap data reporting, commodity swaps, clearing, swaps processing, margining, segregation, uncleared swaps, execution, portfolio reconciliation, real-time public reporting, trade confirmations, Business Conduct Standards, qualified eligible person, accredited investors, general partnerships, registration, CPO registration requirements, counterparties, swap dealer, major swap participants, MSPs, swap data repository, sell-side firms, buy-side firms, entity-level requirement, reporting party, comment letter, transaction-level requirements, majority ownership, G20, G20 commitments, substituted compliance, transparency, Policy Makers, European Parliament, Council of the European Union, Hong Kong, Hong Kong Monetary Authority, Securities and Futures Commission, Monetary Authority of Singapore, Singapore, International Organization of Securities Commissions, IOSCO, Department of the Treasury, natural person, foreign entity, Dealer, fiduciary, International Monetary Fund, International Bank for Reconstruction and Development, Inter-American Development Bank, Asian Development Bank, African Development Bank, United Nations,

MFA Submits Comments to European Supervisory Authorities in Response to Joint Discussion Paper on Risk Mitigation Techniques04.02.12


MFA submitted a comment letter to the European Supervisory Authorities in response to their Discussion Paper on Draft Regulatory Technical […]

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Topics: Joint Committee of the European Supervisory Authorities European Securities and Markets Authority, ESMA, European Supervisory Authorities, ESA, European Union, EU, over-the-counter derivatives, OTC derivatives, central clearing, risk-based margin requirements, risk mitigation techniques, European Banking Authority, European Insurance and Occupational Pension Authority, European Commission, liquidity, segregation regime, initial margin, posting party, receiving party, bankruptcy-remote, prudentially regulated financial counterparties, PRFC, segregation, netting, margin, investment firms, credit institutions, insurance undertakings, assurance undertakings, reinsurance undertakings, institutions for occupational retirement provision, non-cleared derivative contracts, hedging, prudential regulators, Commodity Futures Trading Commission, CFTC, counterparty credit risk, bilateral initial margin arrangements, variation margin, capital, derivatives markets, net margin, best practices, collateralization, non-cleared OTC derivatives, over-collateralization, highly correlated assets, credit default swap, CDS, interest rate swap, Eurodollar futures, physically-settling forwards, repurchase agreements, security lending agreements, intraday change, segregation of counterparty assets, NPRFC, non-prudentially regulated financial counterparties, NFCs+, non financial counterparties above the clearing threshold, non-cleared derivatives, buy-side firms, asymmetry, current market practice, perceived systemic relevance, systemic importance, uncollateralized, exposures, credit exposure, Basel rules, uniformity of application, due diligence, Basel Committee on Banking Supervision, Basel II, Basel III, creditworthiness, regulatory arbitrage, major swap participants, deep and liquid markets, substantial position in swaps, substantial counterparty exposure, international harmonization of regulations, bilateral exchange, market transparency, covered swap entities, de minimi exception, mark-to-market, standardized method, internal models, competitive advantages, discriminatory distortions, internal model method, legally required transparency, incremental compliance costs, segregated account, independent third party custodian, insolvency estate, tri-party custodial arrangements, bilateral arrangements, non-financial assets, eligible collateral, revaluation, haircuts, EMIR, margin calculations, daily valuation of collateral, dispute resolution procedures, party-specific variables,

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 Letter to Federal Reserve Bank of New York Outlining the Collaborative Work of Dealers and Buy-Side Institutions to Deliver Structural Improvements to the Global OTC Derivatives Market03.01.10


MFA, several buy-side firms, the major swap dealers and other industry trade associations jointly submitted a letter to global regulators, […]

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Topics: G-14 buy-side institution, over-the-counter derivatives, OTC derivatives, G-20, transparency, global data repositories, asset class, central clearing, segregation, credit default swap, CDS, portability, ISDA Credit Derivatives Determinations Committees, International Swaps and Derivatives Association, central counterparties, CCP, DC, product standardization, processing standardization, legal standardization, operational efficiency, mitigating operational risk, risk management, netting, bilateral collateralization arrangements, bilateral derivatives transactions, initial margin, electronification, credit derivatives, CDS clearing, Europe, buy-side firms, OTC bilateral collateral processes, ISDA Governance framework, 2009 ISDA Credit Derivatives Determinations Committees, Auction Settlement and Restructuring CDS Protocol, Small Bang, Modified Regstructuring Credit Event, Thomson Restructuring, DC External Review procedure for the Cemex S.A.B de C.V. Restructuring Credit Event, interest rate derivatives, Overnight Index Swaps, OIS, single name clearing, dispute resolution procedures, Raodmap for Collateral Management, collateralized portfolios, margin calls, Equity Derivatives Markets, commodities, foreign exchange, global Interest Rate Reporting Repository, IRRR, eligible trades, Depository Trust & Clearing Corporation, DTCC, Warehouse Trust, zero coupon swaps, single currency basis swaps, forward rate agreements, cross-currency swaps, caps, floors, European swaptions, inflation swaps, default management, inter-dealer service, clearing house, Master Confirmation Agreement, MCA, European Interdealer Index Swap Annex, EMEA EM Options Annex, European Interdealer Fair Value Swap Annex, Roadmap for Collateral Management, Dispute Resolution Procedure, DRP, Market Review of Collateralization, Feasibility Study for Extending Collateralized Portfolio Reconciliations, Implemenation Plan for Wider Market Roll-out, central settlement, settlement automation, Interoperability, trade date matching, novation consent process, Electronically Eligible Products, Confirmable LIfecycle Events, electronic confirmation targest, submission timeliness, matching, confirmation backlog reduction, cash flow matching, rates allocation commitment, electronic allocation delivery functionality, Allocation Industry Working Group,