MFA Comment Letters

Topic: connectivity

Comment Letter on IOSCO’s Consultation Report on ‘Regulatory Issues Raised by the Impact of Technological Changes on Market Integrity and Efficiency,’08.12.11


MFA submitted comments to IOSCO on its consultation report on Regulatory Issues Raised by the Impact of Technological Changes on […]

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Topics: Mr. Werner Bijkerk International Organization of Securities Commissions, Spain, Technical Committee of the International Organization of Securities Commissions, OSCO, Regulatory Issues Raised by the Impact of Technological Change on Market Integrity and Efficiency, Consultation Report, high frequency trading, HFT, market trends, technological developments, institutional investors, pensions, endowments, foundations, insurance companies, market liquidity, Economic Growth, market efficiencies, market access, market information, transaction fees, order execution, Technical Committee, empirical data, algorithmic trading, trading strategies, Gomber, Arndt, Lutat, Uhle, transaction delivery, Peter Gomber, electronic markets, computer programs, monopolies, proprietary, investment time horizons, low latency, broker dealers, sponsored access, spreads, fees, execution speed, market depth, efficiency, transparency, pricing reliability, TAGG Group, fixed commission rates, Schwab, E-Trade, Fidelity, TD Ameritrade, passive, long-term, mutual funds, algorithms, proprietary trading tools, executing brokers, third party vendors, buy-side brokers, fiduciary obligation, educational campaigns, Flash Crash of May 6, 2010, flash crash, market dislocations, Dow Jones Industrial Average, Market Break of 1962, Securities Exchange Commission, SEC, 1963 Special Study of the Securities Markets, 1963 Special Study, New York Stock Exchange, dark pools, wait-and-see, single-stock circuit breakers, CFTC, Joint Advisory Committee on Emerging Regulatory Issues, bid-ask spreads, Thomson, NBBO, Barclays Capital Equity Research, EU, Japan, Germany, UK, France, Nasdaq, Merrill Lynch, Goldman Sachs, LaBranche, Barclays Plc., institutional investor, Financial Crisis of 2008, Rosenblatt Securities, AIG, Fannie Mae, Freddie Mac, Washington Mutual, Market Crash of 1987, intermediary firm, DEA, circuit breakers, limit-up/limit-down systems, erroneous trades, Elizabeth Murphy, Joint Industry Limit Up-Limit Down Proposal, two-sided displayed quotes, oversight, affirmative stock locate framework, ETFs, quote stuffing, order-to-trade ratios, co-location services, standardize disclosure, connectivity, TABB Group, effective spreads in European equities, Division of Risk, Strategy and Innovation memorandum, threshold securities, National Securities Clearing Corporation, NSCC, Office of Markets in the Division of Risk, Strategy and Financial Innovation,

Comment Letter to the CFTC on its Proposed Rules on Risk Management Requirements for Derivatives Clearing Organizations03.21.11


MFA submitted a comment letter to the CFTC on its proposed rules on Risk Management Requirements for Derivatives Clearing Organizations. […]

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Topics: Commodity Futures Trading Commission CFTC, Risk Management Requirements, derivatives clearing organizations, DCO, participant eligibility, eligibility standards, fair and open access, clearing member, DCO concentration risk, diversity of market participants, competition, capital requirements, clearinghouses, swap portfolio size, transaction volume, antitrust considerations, $50 million upper limit, minimum capital requirements, net capital obligation, risk exposure, risk-based methodologies, stress and default scenarios, tiers, threshold guaranty fund contribution, direct clearing members, DCO margin methodologies, guaranty fund scaling methodologies, margin, obligations, cleared trade volumes, scaling requirements, Chicago Board of Trade, committee on payment and settlement systems and technical committee of the International Organization of Securities Commissions, CPSS-IOSCO standards, product eligibility, Designated Contract Market, DCM, Swap Execution Facility, SEF, electronic execution, connectivity, standard two-way protocols, executing counterparty, risk management, margin requirements, market liquidity, initial margin, five-day liquidation horizon, highly liquid instruments, market volatility, on-the-run 10 year interest rate swaps, initial margin requirements, excess margin, default management framework, customer initial margin, direct clearing members' initial margin, credit risk, Columbia University, leverage ratio, investment banks, hedge fund industry, non-hedge positions, product portfolio, swap portfolio, margin methodology, creditworthiness, counterparty credit assessment practices, margin calls, mark-to-market variations, volatility, bilateral trades, greater market concentration, systemic risk mitigation, Bank of America-Merrill Lynch, The Turner Review, global banking crisis, margin calculation utility, effective date, phase-in period, mandatory central clearing, differentiated margining, portfolio margining, cross product margin, swaps, futures, federal register, Federal Reserve Bank of New York, ISDA, SEC, Securities and Exchange Commission,

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,
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