MFA Comment Letters

Topic: CEA

Comment Letter to the CFTC on its Proposed Core Principles and Other Requirements for Swap Execution Facilities03.08.11


MFA submitted a comment letter to the CFTC on its proposed Core Principles and Other Requirements for Swap Execution Facilities. […]

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Topics: Commodity Futures Trading Commission CFTC, swap execution facilities, SEFs, SEF trading platforms, regulatory efficiencies, market efficiencies, market-based competition, transparency, real-time public reporting of swap transaction data, available for trading, competition, grandfather relief, request for quote, RFQ, order book, cleared swaps, block trades, timing delay, required transactions, Designated Contract Market, DCM, Mandatory Execution Requirement, annual review, market liquidity, minimum block threshold, large notional transaction size threshold, reporting requirements, recordkeeping requirements, daily trading records requirements, major swap participants, CEA, RFQ system, Over-the-Counter, OTC, electronic platform, one-to-one voice services, mandatory objective criteria, mandatory transparent criteria, OTC market, connectivity, grace period, liquidity, resting bids, swap data repositories, liquidity characteristics, bilateral trading environment, trading venues, dealer-to-customer platforms, exchanges, swap execution, bilateral trading, voice-based trading, flexibility, execution protocol, order book systems, multiple-to-multiple trading venues, limit order, central limit order variants, non-continuous liquidity, credit default swaps, responsive quote, interstate commerce, mandatory minimum required recipients, quote requesters, institutional investors, voice-based system, security-based swap execution facility, SB SEF, permitted transactions, block trade thresholds, block size, data analysis, minimum block sizes, joint the trade, auction-based methods, matching, fixing, open outcry trading pits, quote-requesting participant, widened bid/offer spreads, exchanges for physical, exchanges for swaps, off-market transactions, linked transactions, packaged transactions, single joint transactions, crossing, matching traders, futures position, physical position, cash position, debt instrument, physical contract, discreet contract, Manipulation, price distortion, congestion, sporadic liquidity, emergency procedure, public information, complete audit trail, conflicts of interest, chief compliance officer, ISDA, SIFMA, Over-the-Counter Derivatives Markets, CBOE futures exchange, RFQ response period, Rulebook,

MFA Letter to FTC on Prohibition of Energy Market Manipulation Rule05.20.09


MFA jointly with FIA, CME Group, ICE and NFA submitted a letter to the Federal Trade Commission regarding its “Prohibition […]

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Topics: Federal Trade Commission FTC, Market Manipulation Rulemaking, futures group, Part 317, anti-manipulation protections, non-futures, wholesale markets, crude oil, gasoline, commodities, Manipulation, fraud proscriptions, Commodity Futures Trade Commission, CFTC, petroleum distillates, exclusive jurisidiction provision, safe harbor, federal register, exclusive jurisdiction provision, price discovery, forward market business activities, regulatory, CEA, anti-manipulation system, false reports, commodity prices, resource limitations, congressional grant, energy markets, John M. Damgard, Futures Industry Association, FIA, Jerrold E. Salzman, CME Group Inc., Thomas W. Sexton, National Futures Association, NFA, Jeffrey Sprecher, IntercontinentalExchange, ICE, Donald S. Clark, Advanced Notice of Proposed Rulemaking, wholesale purchase, options trading, energy futures, futures exchange, Chciago Mercantile Exchange Inc., Board of Trade of the City of Chicago, Inc., CBOT, new York Mercantile Exchange Inc., NYMEX, Commodity Exchange, COMEX, ICE Futures U.S., New York Board of Trade, ICE Futures of Europe, ICE Futures Canada, Winnipeg Commodity Exchange, over-the-counter energy trading platform, commercial market, limited-purpose national securities association, customer protection, merchants, brokers, commodity pool operators, commodity trading advisors, registered account executives, sugar, corn, ethanol, price effects requirements, compliance burden, U.S. Court of Appeals for the Seventh Circuit, Board of Trade of City of Chicago v. SEC, 677 F.2d 1137 (7th Cir. 1982), Chicago Mercantile Exch. v. SEC, 883 F.2d 537 (7th Cir. 1989), Board of Trade of City of Chicago v. SEC 677 F.2d 1137, 1145 (7th Cir. 1982), FTC v. Roberts, 276 F.3d 583 (D.C. Cir. 2001), 276 F.3d at 592, chain of precedent, 276 F.3d at 591, SEC vs. Hopper, corporate disclosures, US vs. Reliant Energy Services, 420 F Supp.2d 1043 (N.D. Cal. 2006), exclusive regulatory authority, Federal Energy Regulatory Commission, FERC, instruments, accounts, Ken Roberts Co. v. FTC, No. 01-1772, 537 U.S. 820, 2002 WL 32135703, speculative limits, Energy Department, DOE, Environmental Protection Agency, EPA, emissions credit, Agriculture Department, USDA, Williamson v. United States, 512 U.S. 594, Trichilo v. Sec'y of Health & Human Servs., 823 F.2d 702, 706 (2d Cir. 1987), SEC v. American Commodity Exch., 546 F.2d 1361, International Trading Ltd. v. Bell, 556 S.W.2d 420 (Ark. 1977), Clayton Brokerage Co. v. Mouer, 531 S.W.2d 805 (Tex. 1975), Minnesota v. Coin Wholesalers, 250 N.W.2d 583 (Minn. 1976), Amaranth, statutory authority, non-petroleum based commodities, agricultural feed-stocks, price artificiality, contract markets, intermediaries, agents, counterparties, contractual privity, contradictory requirements, United States Congress, 2006 WL 778640 (S.D. Tex. March 24 2006),
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