MFA Comment Letters

Topic: credit

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 Submits Letter to IRS on Proposed Rules on Dividend Equivalent Payments04.06.12


MFA submitted a comment letter to the Internal Revenue Service on the IRS proposed rules under Section 871(m) of the […]

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Topics: Internal Revenue Service IRS, dividend equivalent, tax avoidance, market participants, contractual representations, undue market disruption, swaps, delta-one instruments, customized index, derivatives, equity linked derivatives markets, in connection with standard, in the market, crossing transactions, short-term trades, high-frequency trading, gross witholding, cascading witholding taxes, special dividends, witholding agent, FATCA, specified notional principal contracts, SNPC, outstanding positions, dividend equivalent payments, abusive practices, non-U.S. persons, out-of-the-money, equity-linked swaps, options, futures, underlying security, strike price, dividend payment, dividend swaps, long-party, short-party, future dividend flow, anti-abuse rule, delta-one, International Swaps and Dealers Association, ISDA, delta, delta one instrument, non-delta one instrument, 90-Day Rule, retested, market forces, broad-based indices, market sector, credit, leverage, trading strategies, recognized independent index publisher, options contracts, proprietary index, preferred stock, common stock, illiquid securities, derivatives transactions, private funds, public float, hedge, synthetic exposure, offsetting position, individual trade determinations, investment algorithms, compliance restrictions, long equity swap, investment fund, single strategy fund, multi-strategy fund, average daily trading volume, ADTV, public float test, Bloomberg, direct or indirect "cross", crossing, full notional amount, internal tax review system, real-time identification of offsetting positions, 30 day liquidity, Department of the Treasury, overwitholding, extraordinary dividend, Options Clearing Corporation, OCC, ordinary divident, special dividend, OTC option, options market,

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,

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,

MFA Comments to U.S. Federal Banking Agencies on Capital Treatment of Equity Investments in Hedge Funds by Banks in Proposed Regulations Implementing Basel II International Capital Accords06.21.07


MFA submits comment letter to the U.S federal banking agencies on the capital treatment of equity investments in hedge funds […]

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