MFA Comment Letters

Topic: creditor

MFA Submits Amicus Brief on Issue of Creditor Coordination06.29.12


On June 29, MFA filed an amicus brief in the 11th Circuit en banc review of the CompuCredit case.  At […]

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Topics: U.S. Court of Appeals for the Eleventh Circuit Compucredit Holdings Corporation v. Akanthos Capital Management LLC, Loan Syndications and Trading Association, Securities Industry and Financial Markets Association, SIFMA, Moses Silverman, Aidan Synnott, Daniel Crane, Financial Crisis Inquiry Commission, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, FDIC, Office of the Comptroller of the Currency, Edward Altman, Brendy Kuehne, New York University Salomon Center, Stern School of Business, John Coffee Jr., William Klein, Conrad Duberstein, Tomotaka Fujita, Marcel Kahan, corporate bonds, Michael MacKenzie, Nicole Bullock, Glenn Merrick, Ali Stoeppelwerth, banks, investment banks, broker-dealer, alternative investment industry, securities firms, capital formation, chilling effect, borrowers, distressed debt, contractual relationship, interest rates, creditor, credit squeeze, credit market, bonds, secondary loan markets, institutional lender, leverage, systemic risk, Shared National Credit Review, syndicated loan market, Bondholder, maturity date, debtor, Bankruptcy Filing, Bankruptcy Code, collective action risks, capital, primary market, risk portfolio, U.S. Court of Appeals for the Seventh Circuit, Judge Easterbrook, U.S. Court of Appeals for the Second Circuit, price-fixing, hedge funds, price competition, contract, bilateral monopoly, per se rules, par value, debt instruments, high-velocity market, low-velocity market, creditor coordination, market power, anticompetitive, competition, pre-packaged bankruptcy, Broad. Music Inc. v. Columbia Broadcasting Sys. Inc, Bus. Elecs. Corp. v. Sharp Elecs. Corp., Classic Cheesecake Co. Inc. v. JPMorgan Chase Bank NA, Falstaff Brewing Corp. v. New York Life Ins. Co., Federal Trade Commission v. Brown Shoe Co., Federal Trade Commission v. Indiana Federation of Dentists, Federal Trade Commission v. Superior Court Trial Lawyers Association, Finnegan v. Campeau Corp., United States v. Giordano, Ireland v. Craggs, Leegin Creative Leather Products Inc. v. PSKS Inc., Arizona v. Maricopa County Medical Society, Maris Distrib. Co. v. Anheuser-Busch Inc., National Collegiate Athletic Association v. Board of Regents, Northwest Wholesale Stationers Inc. v. Pacific Stationery & Printing Co., Palmyra Park Hosp. Inc. v. Phoebe Putney Memorial Hospital, Reisner v. General Motors Corp., Reiter v. Sonotone Corp., Sharon Steel Corp. v. Chase Manhattan Bank NA, Smith v. The Ferncliff, State Farm Mutual Auto. Ins. Co. v. Physicians Injury Care Center Inc., United States v. Topco Assocs Inc., Twin City Pipe Line Co. v. Harding Glass Co., Unijax Inc. v. Champion International Inc., United Airlines Inc. v. U.S. Bank NA, Volt Info. Scis. Inc. v. Board of Trs. of Leland Stanford Jr. University,

MFA Submits White Paper to European Commission on Shadow Banking06.01.12


On June 1, MFA submitted a white paper on hedge funds and shadow banking in response to the European Commission’s […]

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Topics: European Commission European Union, EU, Green Paper "Shadow Banking", shadow banking, shadow banking system, systemic risk, Background Note, Background Note "Shadow Banking: Scoping the Issues", Financial Stability Board, FSB, hedge fund industry, credit hedge funds, leverage, investor, counterparties, regulatory framework, regulatory arbitrage, financial industries, mutual funds, banks, financial market, investment strategies, asset classes, liquidity transformation, maturity transformation, risk analysis, liquidity protections, liquidity, equity investors, financial institutions, demand deposit accounts, collateral, margin, deposit-like characteristics, redemption terms, secured borrowings, direct lending, direct loan market, AIFMD, Alternative Investment Fund Managers Directive, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, originator, derivative transactions, total return swaps, secured financing, credit intermediation, non-bank financial insitutions, bank-like activities, maturity tra, G20, nonbank credit intermediation, hedge fund counterparties, broker-dealer, risk management, hidden leverage, bank-like regulation, assets under management, AUM, Securities and Exchange Commission, SEC, state securities regulators, regulatory assets under management, RAUM, U.S. Securities Laws, chief compliance officer, hedge fund managers, Form ADV, investment advisers, Form PF, Commodity Futures Trading Commission, CFTC, Financial Stability Oversight Council, FSOC, commodity futures contracts, swaps, commodity pool, commodity trading advisor, CTA, over-the-counter derivatives, OTC derivatives, central clearing, derivatives, segregation, transparency, major swap participants, swap dealers, derivatives market, Office of Financial Research, OFR, systemically important financial institution, SIFI, Board of Governors of the Federal Reserve System, the Fed, prudential regulation, Doug Elliott, Brookings Institution, absolute risk, Volcker Rule, Long Term Capital Management, "too big to fail, government insurance, market based regulations, House Financial Services Subcommittee on Financial Institutions and Consumer Credit, private equity, venture capital funds, property-casualty insurance, mutual funds management, money market funds, public company equity securities, institutional investment manager, insider trading, Department of the Treasury, Bureau of Economic Analysis, EU Member State, MiFID, Markets in Financial Instruments Directive, European Market Infrastructure Regulation, EMIR, Investment Company Institute, ICI, United Kingdom, counter-cyclical, creditor, taxpayer, sophisticated investors, instant liquidity funds, discount windows, gates, lock-up periods, side pockets, Financial Services Authority, FSA, uncollateralized loans, initial margin, variation margin, asset-backed commercial paper conduits, ABCP conduits, structured investment vehicles, SIV, Columbia University, leverage ratio, Lord Adair Turner, Hedge Fund Research, asset-backed securities, corporate bonds, government bonds, small and medium-sized enterprises, SME, leveraged loan markets, quantitative strategies, credit arbitrage strategies, fundamental credit analysis, distressed restructuring strategies, fixed income instruments, bankruptcy, private issue/Regulation D strategies, Regulation D, private investment in public equity, PIPE, relative value, pricing discrepancy, fixed income - asset backed, loans, credit cards, receivables, real estate, tangible financial commitments, fixed income - convertible arbitrage, convertible arbitrage, fixed income - corporate, corporate fixed income instrument, relative value - multi-strategies, Master Limited Partnership,

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

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Topics: private funds commodity pool operators, commodity trading advisors, Form PF, systemic risk, Financial Stability Oversight Council, market participants, managed futures, absolute return strategies, SEC, CFTC, Dodd-Frank Act, Council and Office of Financial Research, OFR, global regulators, overcounting, undercounting, threshold for enhanced performance, assets under management, reporting period, confidentiality protections, inadvertent disclosure, non-bank financial companies, lending institutions, interconnectedness, liquidity risk, maturity mismatch, regulatory scrutiny, systemically significant, Federal Reserve System, the Fed, Form CPO, Form PQR, Form CTA-PR, targeted requests, tiered reporting system, threshold, trading and investment strategies, borrowing arrangements, collateral practices, operational capabilities, illiquid assets, investment advisers, bespoke contracts, private equity, privately issued convertible bonds, equity derivatives, distressed debt, unaffiliated third party sources, generally accepted accounting principles, GAAP, Level 2 inputs, Level 3 inputs, Financial Accounting Standards Board, audited financial statements, UK Financial Services Authority, FSA, Form 13F, public companies, Form 10-K, Form 10-Q, portfolio management, CUSIP number, semi-annual reporting, counterparty exposures, market noise, short-term market fluctuations, margin requirements, hedge fund defaults, large private fund manager, qualifying fund, hedge fund assets under management, Form ADV, proposed reporting thresholds, interpretive guidance, private fund managers, recordkeeping requirements, section 404, confidentiality of information, proprietary information, Investment Adviser Registration Depository, Schedule 13G, individual certification, valuation methodology, proprietary methodology, alternative methodology, de minimis, master-feeder, parallel funds, equity prices, interest rates, currency rates, Form PF question 36, form PF questions 28 and 35, funds of funds, direct investments, aggregate gross asset value, collateral, operational efficiency, ten-year option, five-year option, master agreement, regulatory assets under management, net assets under management, leverage, parallel managed accounts, net asset value, gross asset value, creditor, net borrowings, aggregate borrowings, beneficial owners, record owners, fixed advisory fees, investment expenses, performance fees, inception class, statistical arbitrage-equity, other quantitative strategies, strategy exposure, risk capital allocation, NAV, futures commission merchants, FCMs, direct clearing members, DCMs, prime brokers, clause (iii), loan commitments, offsetting exposure, tri-party collateral accounts, market value, asset-backed securities, debt securities, swap contracts, futures contracts, foreign currency contracts, notional value of derivatives, notional amount, long positions, short positions, LMV, SMV, maturity brackets, short-term interest rate, DV01, CR01, duration, non-rated issues, short term high quality corporate debt, foreign exchange derivatives, turnover rate, GMV, Bloomberg, risk methodology, repos, sensitivity analyses, liquidity management, balance sheet value, delta adjusted, variation margin, equity exposure, rehypothecated initial margin, CCPs, central clearing counterparties, Value at Risk, VaR, CDS, CDX, default rates, corporate bonds, short borrowing, synthetic borrowing, uncommitted lines of credit, side pocket arrangement,

Comment Letter Responding to FDIC’s Proposed Rules to Implement Certain Provisions of the Orderly Liquidation Authority in Title II of the Dodd-Frank Act.01.18.11


MFA filed a comment letter with the Federal Deposit Insurance Corporation (the FDIC) in response to the FDICs proposed rules […]

MFA Comments on CFTC Regulatory Intitiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

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Topics: Commodity Futures Trading Commission CFTC, Securities and Exchange Commission, SEC, financial regulatory system, hedge funds, financial crisis, institutional investors, OTC derivatives market, over-the-counter derivatives market, systemic risk, operational risk, transparency, capital markets, U.S. Banking Industry, Columbia University, Investment Company Institute, Federal Financial Institutions Examination Council, leverage, private investment funds, Investor Protection, market discipline, investor confidence, market stability, risk capital, proprietary strategies, international coordination, financial risk, business risk, swap dealer, swap, Counterparty, market maker, futures commission merchant, FCM, futures, Major Swap Participant, msp, non-swap dealer, AIG, initial margin, variation margin, substantial position, offsetting position, clearing, central clearing, liquidity, regulatory capital requirements, creditor, depositor, Tier 1 capital, pension plans, endowments, cleared swaps, uncleared swaps, security-based swaps, collateral, non-bank MSP, Swap Execution Facility, SEF, equity market, futures market, risk management, central counterparties, CCP, risk model, customer protection, risk committee, proprietary asset, customer asset, third party custodian, segregation, omnibus account, individual account, reporting, Designated Contract Market, market integrity, physical market, position limits, contract market, commodity trading advisor, CTA, investment adviser, Peavey Commodity Futures Fund no-action letter, commodity pool operator, Financial Stability Oversight Council, FSOC, Office of Financial Research, owned funds, residual value, managed funds, investment portfolio, roll-over, commercial paper, credit exposure, Federal Deposit Insurance Corporation, FDIC, Troubled Asset Relief Program, TARP, Federal Reserve, "too big to fail, bankruptcy law, Bondholder,

MFA Comments on SEC Regulatory Initiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

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Topics: Commodity Futures Trading Commission CFTC, Securities and Exchange Commission, SEC, financial regulatory system, hedge funds, financial crisis, institutional investors, OTC derivatives market, over-the-counter derivatives market, systemic risk, operational risk, transparency, capital markets, U.S. Banking Industry, Columbia University, Investment Company Institute, Federal Financial Institutions Examination Council, leverage, market discipline, investor confidence, market stability, risk capital, proprietary strategies, international coordination, financial risk, business risk, swap dealer, swap, Counterparty, market maker, futures commission merchant, FCM, futures, Major Swap Participant, msp, non-swap dealer, AIG, initial margin, variation margin, substantial position, offsetting position, clearing, central clearing, liquidity, regulatory capital requirements, creditor, depositor, Tier 1 capital, pension plans, endowments, cleared swaps, uncleared swaps, security-based swaps, collateral, non-bank MSP, Swap Execution Facility, SEF, futures market, risk management, central counterparties, CCP, risk model, customer protection, risk committee, proprietary asset, customer asset, third party custodian, segregation, omnibus account, individual account, reporting, Designated Contract Market, market integrity, physical market, position limits, contract market, commodity trading advisor, CTA, investment adviser, Peavey Commodity Futures Fund no-action letter, commodity pool operator, Financial Stability Oversight Council, FSOC, Office of Financial Research, owned funds, residual value, managed funds, investment portfolio, roll-over, commercial paper, credit exposure, Federal Deposit Insurance Corporation, FDIC, Troubled Asset Relief Program, TARP, Federal Reserve, "too big to fail, bankruptcy law, Bondholder, private investment funds, mutual fund, client, pooled vehicle, pooled investment vehicle, Investor Protection, self-regulatory organization, SRO, investment adviser examination, Comptroller General of the United States, capital formation, Office of Compliance Inspections and Examinations, OCIE, private funds, global banks, retail clients, proprietary information, Confidential Information, Venture Capital Fund, family office, accredited investor, qualified client, knowledgeable employees, transitional relief, performance reports, market makers, Broker, fiduciary, Major Security-Based Swap Participant, MSSP, registration, margin requirement, risk profile, financial entities, Price Manipulation, executive compensation, many-to-many platform, covered financial institution, Incentive-Based Compensation Arrangements, Regulation D, disqalifying felons, Bad Actors, CUSIP number, short selling, Disclosure, price discovery, volatility, retail funds, global market, equity market, herding, Form SH, beneficial ownership, short swing profit reporting, fiduciary standard, Investor Advisory Committee, European Commission, EC, European Union, EU, European Parliament, EP, European Council of Finance Ministers, alternative investment funds, AIFs, SEC-registered advisers, Secretary Geithner, European Commissioner Michel Barnier, U.K. Chancellor of the Exchequer Alistair Darling, non-bank financial companies,
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