MFA Comment Letters

Topic: clearing agreement

MFA Submits Letter to ESMA on Straight-Through-Processing08.05.12


On August 5, MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) to advocate for the […]

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Topics: ESMA European Securities and Markets Authority, OTC derivatives, CCP, trade repositories, straight-through processing, regulatory technical standards, EMIR, over-the-counter derivatives, derivatives, European Parliament, Council of the European Union, OTC derivatives transactions, central counterparty, systemic risk, counterparty credit risk, credit risk, market access, efficiency, operational market processes, clearing, execution, executing counterparty, market participants, clearing obligation, documentation, clearing member, interest rate swap, credit default swap, CDS, CME, Chicago mercantile exchange, alternative liquidity providers, liquidity, risk, electronic trading, bilateral derivatives transactions, bilateral master agreements, risk management, real-time processing, Commodity Futures Trading Commission, CFTC, Designated Contract Market, DCM, Swap Execution Facility, SEF, execution platform, Allocations, cost-benefit analysis, European Union, EU, ESMA Task Forces, transparency, OTC Derivatives Task Force, CCP Requirements Task Force, Trade Repositories Task Force, derivatives transactions, international harmonization of regulations, Financial Stability Board, FSB, European Commission, delegated acts, customer clearing documentation, directive, due diligence, operational risk, Court of Justice of the European Union, Continental Cans, EU Member State, Commission v. Council ERTA, financial stability, Christopher Seagon v. Deko Marty Belgium NV, clearing agreement, financial system, United States, Dodd-Frank Act, real-time acceptance, competition, settlement, liquidity fragmentation, central limit order books, International Swaps and Dealers Association, ISDA, bid-ask spread, limit check, trading venues, credit intermediation, derivatives markets, bilateral risk management, volatility, derivatives clearing organization, DCO, swap dealer, Major Swap Participant, dealer-to-dealer clearing, dealer-to-customer platforms, mandatory clearing, clearinghouse, bilateral credit agreement, bilateral market, competitive liquidity, block transactions, investment managers, breakage, Futures Industry Association, FIA, trading desk, anti-competitive effects, ICE energy swaps, ICE Clear Credit LLC, LCH Clearnet, clearing acceptance process, trilateral documentation, designation notice, Managed Funds Association, bundled trade, futures, futures market, credit limit order bookc, credit limit, interconnectedness, dealers, real economy, pension fund, endowments, institutional investors, Liquidity Providers, trilateral clearing agreements, energy derivatives, technical standards, voice execution, matched transactions, direct clearing members, credit limits, risk-based, latency, transaction capture facility, anti-competitive restrictions, aggregate limit, underlying clients,

Supervisory Commitment Letter on OTC Derivatives Initiatives03.31.11


The MFA, along with several other major financial institutions, submitted this letter to William C. Dudley of the Federal Reserve […]

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Topics: Federal Reserve Bank of New York G-14, buy-side institutions, signatories, Over-the-Counter, OTC, derivatives, OTC derivatives risk management, market structure, OTC Derivatives Supervisors Group, central clearing, bilateral risk management, transparency, Federal Reserve System, Commodity Futures Trading Commission, CFTC, Connecticut Banking Department, Federal Deposit Insurance Corporation, Federal Reserve Bank of Richmond, Autorite de Control Prudential, ACP, German Federal Financial Supervisory Authority, Japan Financial Services Agency, New York State Banking Department, Office of the Comptroller of the Currency, Securities and Exchange Commission, SEC, Swiss Financial Market Supervisory Authority, United Kingdom Financial Services Authority, Alliance Bernstein, Bank of America-Merrill Lynch, Barclays Capital, Blackrock Inc, Blue Mountain Capital Management LLC, BNP Paribas, Citadel LLC, Citi, Credit Suisse, Deutche Bank AG, D.E. Shaw & Co L.P., DW Investment Management LP, Goldman, Sachs & Co, Goldman Sachs Asset Management L.P., HSBC Group, International Swaps and Derivatives Association Inc, J.P. Morgan, Managed Funds Association, Morgan Stanley, Pacific Investment Management Company LLC, The Royal Bank of Scotland Group, Asset Management Group of the Securities Industry and Financial Markets Association, Societe Generale, UBS AG, Wells Fargo Bank N.A., Wellington Management Company LLP, Committee on Payment and Settlement Systems, European Commission, European Central Bank, European Securities Markets Authority, Financial Stability Board, Bank of England, international regulatory coordination, standardization, data reporting, flexibility, market regulation, global derivatives, reporting, G20, automated processing, uncleared transactions, disputed margin calls, steady state, standardization benchmarking, standardization matrix, standardization narrative, flow/activity data, quantitative stock, credit, equity, interest rates, column-wise functional area, Commodities Steering Committee, Commodities Major Dealers, CMD, Foreign Exchange/Currency Derivatives Major Dealers, Simple instruments, Complex Exotic Instruments, Financial Markets lawyers Group, FMLG, baseline metrics, Equity Derivatives Definitions, 2011 EDDs, Master Confirmation Agreements, MCA, Matrix Working Group, Transaction Supplement, Equity Steering Committee, ESC, operation efficiency targets, trade repositories, infrastructure providers, matching and confirmation, affirmation, lifecycle events, Credit Implementation Group, CIG, equity derivative, operational performance targets, electronically eligible conformations, platform convergence, trade lifecycle event processing, Equity Determinations Committee, EDC, Interest Rate Derivative, functionality, middleware platforms, granularity, Trade Date submission, currently eligible transactions, statutory clearing requirements, submission targets, uncollateralized payable, offsetting CDS hedge, direct buy-side clearing models, indirect buy-side clearing models, product pipeline, sovereigns, FRAs, amortizing swaps, HUF, CZK, SGD, enhanced financial safeguards, cross-currency swaps, caps, floors, European swaptions, inflation swaps, trade date repositories, enhanced clearing penetration, clearing agreement, client onboarding, client collateral, risk issues, compression requirements, margin requirement, liquidity, CPSS-IOSCO, credit default swap, CDS, ISDA Credit Derivatives Determinations Committees, DC, CCP, CDS central counterparties, ISDA 2011 convention on Portfolio Reconciliation and the Investigation of Disputed Margin Calls, ISDA 2011 Formal Market Polling Procedure, Dispute Resolution, portfolio reconciliation, collateral disputes, dispute reporting, prudential regulator, ISDA Minimum Market Standards for Portfolio Reconciliation, electronic messaging, portfolio compression, commodity derivatives, foreign exchange derivatives, interest rate derivatives, residual risk position, regular compression cycles, tear-up algorithms, compression MIS, automatic compression, FX derivatives, aggregate compression yields, trade repository infrastructure, market participants, international data standards, IGC Data Working Group, DWG, legal entity identifiers, LEI, FpML Standards Committee, tradable instruments, cost-recovery, standardized representation, unique product identifiers, Interest Rate Derivatives Trade Reporting Repository, IRRR, Request for Proposal, RFP, Phase II Repository Reporting Expectations, OTC Derivatives Regulatory Forum, ODRF, transaction level data submissions, trade pairing process, COSC, FXMD, International Organization of Securities Commissions, IOSCO, LEAP, EFET, ISDA, IETA, LMBA, copper records, Warehouse Trust, New "Gold" Products, Trade Information Warehouse, recovery lock transactions, client data confidentiality, EMIR legislation, FX Volatility Swap, Cross-Currency Guide, FX Novation Protocol, European Interdealer Index Swap, European Interdealer Fair Value Swap, EMEA EM Interdealer Options, Cash Flow Matching for Equity Derivative Transactions, Allocations, Trade Affirmation, Interoperability, MarkitSERV, MarkitWire, DTCC, Credit Derivative Tranche Transactions, Sukuk Corporate, ISDA Credit Derivatives Physical Settlement Matrix, Credit Derivatives 2010 Documentation Update Working Group, CDD, Small Bang Protocol, Restructuring Credit Event, Anglo Irish Bank Corporation Limited, novation consent, Novation Consent Platform, European MBS, Fixed Recovery Swaps, Swaptions on Indices, iTraxx Europe Untranched Swaption transactions, CDX Untranched Swaption transactions, NDOs, Vanilla Options, Simple Exotic Options, Core FX, NDFs, Continuous Linked Settlement system, CLS, dealer to dealer clearing, LCH.Swapclear, Rates TRR aggregate reporting, zero coupon swaps, single currency basis swaps, extending operating hours, end user clearing, ICE Trust, ICE Clear Europe, dispute resolution procedures, inter alia, Global Compression, CLS Aggregation Service, Core FX settlement processing, ODSG, Equity Derivative Reporting Repository, EDRR, trickle down effect,

Supplementary Letter to the SEC in Response to its Proposed Antifraud Rule with Respect to Security-Based Swaps03.29.11


MFA submitted a letter to supplement our December 23, 2010 letter to the SEC in response to its proposed antifraud […]

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Topics: Securities and Exchange Commission SEC, Fraud, Manipulation, Deception, security-based swaps, anti-fraud rule, security based swaps market, cost-benefit analysis, honest markets, legitimate market activity, US OTC derivatives market, derivatives market, swaps market, legitimate market participation, purchase, sale, definitions, statutory authorization, security based swap anti-fraud rule, Securities Industry and Financial Markets Association, International Swaps and Derivatives Association Inc, The Loan Syndications and Trading Association, maturity date, context, bilateral contracts, novations, unwinds, assignments, execution, termination, assignment, exchange, transfer of rights/obligations, conveyance of rights/obligations, extinguishment of rights/obligations, total return swaps, credit default swaps, transferor, credit events, corporate actions, underlying shares, disruption events, termination events, collateral, systemic risk, interim payments, premium payments, spread payments, material non-public information, ISDA master agreement, clearing agreement, counterparty defaults, bankruptcy proceedings, Bankruptcy Code, automatic stay provisions, price discovery process, fair dealing, competition, capital formation, Financial Crisis Inquiry Commission, single name credit default swaps, non-index multi-name credit default swaps, equity linked forwards, equity-linked swaps, unallocated swaps, Bank of International Settlements, BIS, price discovery, primary participant, secondary participant, credit exposure, equity exposure, institutional leveraged loans, investment grade bonds, Financial Stability Board, primary debt issuance, investment grade loans, leveraged loans, LBO-related loans, corporate loans, high yield bonds, Loan market Review, Reuters, SEC v. Rotech, FCIC, CDS market, swap market, financial crisis, price efficiency, investor confidence, material dislocation,

Letter to Mary Schapiro; Attachments: (Industry Letter on Buy Side Access to Clearing) and (Recommended Timeline for Adoption and Implementation of Final Rules Pursuant to Title VII of The Dodd-Frank Act)03.24.11


MFA submitted a letter to Chairmen Schapiro and Gensler, and each of the SEC and CFTC Commissioners, providing our recommendations […]

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Topics: Securities and Exchange Commission OTC derivatives market, reform, systemic risk, efficiency, global financial system, central clearing, liquid contracts, clearable contracts, trade repositories, cleared swaps, bilateral swaps, price transparency, liquid swap transactions, broad industry clearing, trade repository data, electronic data, trade transparency, buy-side participants, buy-side access, New York Fed, ISDA Governance Committee, IIGC, standardizing contracts, trade compression, OTC derivatives reform, milestones, phase-in period, sell-side firms, clearinghouses, Regulators, current clearable swaps, future clearable swaps, broad-based index credit default swaps, CDS, interest rate markets, single-name CDS, asset managers, end-users, CCPs, CMs, customer clearing services, open interest caps, waterfalls, block trading, risk compression, customer funds, pre-default portability, give-up agreements, US bankruptcy, non-US bankruptcy, cleared OTC derivatives, 14d order, 17f6 order, SEC exemptions, FINRA exemptions, margin methodology, CME rules, CME, ClearPort, migration, TBF, Bloomberg, MarkitWire, ICELink, end to end production testing, front-office processing, middle-office processing, back-office processing, back loading facility, end-to-end systems flow, fallback processing, post-default portability, risk waterfall process, net client omnibus margin account, price challenge protocol, financial disclosure requirements, clearing, commission fee, trading annex, give up process, transparency, default waterfall, futures, CDS books, margin segregation, Basel I capital requirements, FCMs, commodity contracts, Bankruptcy Code, roll-out schedule, margin regime, vendor, streamlined netting process, trade rejection rights, segregation framework, alternative margin segregation schemes, title transfer regime, English law CSAs, US banking regulators, US bank CM, non-US bankruptcy laws, non-US CM's default, position limits, real-time reporting, big bang approach, phase-in approach, derivatives clearing organizations, interest rate swaps, exchange trading, MSPs, hedge funds, dealer-to-dealer clearing, SEF trading, onboarding, mixed swap, swap dealer, eligible contract participant, DCO governance, DCO registration, collateral, Business Conduct Standards, capital requirements, margin requirements, MSP recordkeeping requirements, SD recordkeeping requirements, public reporting, liquidity, individual risk concentrations, block trade. swap initial margin, post-trade reporting, pre-trade reporting, interdealer reporting, Dodd-Frank clearing requirements, clearing agreement, execution agreement, clearing members, FIA, CFTC rules, SEC rules, mandatory clearing date, CCP implementation period, CCP risk management, end-user exemptions, Phase 1 mandatory cleared products, counterparty risk, OTC derivatives, standardized documentation, onboarding work streams, voluntary period, direct clearing participants, indirect clearing participants, voluntary targets, scale readiness, volume targets, simpler instruments, complex instruments, credit, voluntary back loading, compression, systemic counterparty risk, industry-level metrics, DTCC data, cleared settlement, uncleared settlement, tear-ups, long-only accounts, asset manager accounts, investor,
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