MFA Comment Letters

Topic: European Market Infrastructure Regulation

MFA Letter to ESAs on EMIR Risk Mitigation Regulatory Technical Standards07.14.14


MFA submitted a comment letter to the European Supervisory Authorities (ESAs) on their joint consultation paper on “Draft regulatory technical […]

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Topics: European Banking Authority European Insurance and Occupational Pension Authority, European Securities and Markets Authority, ESMA, European Supervisory Authorities, consultation paper, EMIR, European Market Infrastructure Regulation, systemic risk, counterparty credit risk, collateral, OTC derivatives market, market participants, regulatory technical standards, margin, segregation, third country, financial counterparties, non-financial counterparty, clearing threshold, variation margin, initial margin, transparency, G7, harmonization, uncleared derivative, regulatory arbitrage, Basel Committee for Banking Supervision, International Organization of Securities Commissions, IOSCO, Canada, France, Germany, Italy, Japan, United States, United Kingdom, European Commission, duplicative regulation, substituted compliance, equivalence, Cayman Islands, alternative investment funds, AIMA, Alternative Investment Management Association, European Parliament, Council of the European Union, counterparties, mandatory margin requirements, documentation, regulatory requirements, minimum notional threshold, trade repositories, settlement period, netting, trading costs, efficiency, legal opinion, verification requirement, concentration limits, proportionality principle, US Treasuries, securities, liquidity, haircuts, settlement currency, collateral currency, base currency, third party custodian, liquidation, in-scope entity, International Swaps and Derivatives Association, ISDA, dispute resolution procedures, Individual Segregation,

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,

MFA Responds to ECON’s MiFID Questionnaire01.13.12


MFA submitted responses to MEP Markus Ferbers Questionnaire on MiFID/MiFAR 2, which asks for further information on certain aspects of […]

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Topics: Economic and Monetary Affairs Committee ECON, European Parliament, Questionnaire on MiFID/MiFIR 2 by Markus Ferber MEP, Markus Ferber, Markets in Financial Instruments Directive, eligible counterparties, custody, safekeeping, MiFID passport, professional clients, retail clients, equivalence, reciprocal access, regulatory capital, corporate governance rules, Securities and Exchange Commission, SEC, European Commission, management bodies, trading venues, corporate governance, broker crossing network, derivatives trading venues, derivatives, voice brokerage systems, alternative investment managers, alternative investment funds, broker dealers, relevant counterparties, clearing obligation, EMIR, European Market Infrastructure Regulation, central limit order book, CLOB, request for quote system, RFQ, algorithmic trading, high frequency trading, market-making activities, correlating instruments, mutual funds, arbitrage trading, high frequency/low latency, liquidity, flash crash, limit up-limit down measure, counterbalancing benefits, regulatory investigation, direct electronic access, DEA, co-location services, circuit breakers, abnormal trading conditions, confidentiality requirements, organized venues, public consultation, third country trading venues, EEA venues, reciprocal recognition, third country firms, straight-through processing, real-time registration, listed futures, listed equity derivatives, energy swaps, bilateral credit agreement, bilateral execution documentation, CCP, risk caps, SME, MTF SME, non-discriminatory access to market infrastructure, pre-trade market data, position limits, alternative arrangements, commodity derivatives, position management powers, hedging transactions, conflicts of interest, structured UCITS, non-structured UCITS, financial activity, shares, depositary receipts, exchange traded funds, ETF, broker liquidity, transparency, trading obligation, confidentiality safeguards, dark pools, approved publication arragement, APA, approved reporting mechanism, ARM, consolidated tape provider, CTP, European Supervisory Authorities, ESA, non-discriminatory access, real-time clearing, UCITS IV, packaged retail investment product, PRIP, organized trading facility, OTF, sanction,

Letter to the European Commission in Response to its Consultation Paper, Review of the Markets in Financial Instruments Directive (MiFID)02.02.11


MFA submitted comments to the European Commission in response to its Consultation Paper, Review of the Markets in Financial Instruments […]

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Topics: European Commission Markets in Financial Instruments Directive, MiFID, regulatory framework, market stability, risk capital, proprietary strategies, surveillance tools, European Union, EU, financial regulatory system, hedge funds, OTC, commodity derivatives market, Investor Protection, title transfer collateral arrangements, non-retail clients, third country firms, "strict equivalence" regime, electronic trading platforms, liquid derivatives, exchange trading, exchange-traded products, European OTC derivatives markets, US markets, Asian Markets, ESMA, sufficiently liquid, European Commission on Standardisation and Organised Platform Trading of OTC Derivatives, Organised Trading Venues, cost-effective manner, reduced transaction costs, algorithmic trading, broker dealers, market impact, accurate price discovery, high frequency trading, HFT, market makers, low latency technology, strategy holding periods, horizon strategies, fleeting arbitrage opportunities, risk management, electronic market-making, technology-driven market makers, inventory risk, risk exposure, inter-market arbitrage, ultra low-latency technology, capital formation, automated execution technology, global connectivity infrastructure, financial institutions, market connectivity intermediaries, direct market access, flash crash, HFT trades, non-HFT trade, asset managers, insurance companies, banks, brokers, automated trading, arbitraging, minimum quantitative threshold, portfolio manager, alternative investment fund managers, AIFM directive, UCITS Directive, level playing field, non-EU asset managers, risk controls, pre-trade checks, SEC, Securities and Exchange Commission, circuit breakers, market-wide single stock circuit breakers, limit up system, limit down system, speed bumps, trading delays, specified maximum execution speeds, co-location facilities, latency, liquidity, investor confidence, technological innovation, short-term price swings, low latency technology chain, minimum tick sizes, liquid market, deep market, liquidity provision requirements, article 4(8) of MiFID, broker-dealer capital, margin requirements, concentrated risk solution, regulatory "tax, market efficiency, minimum duration of orders, limit orders, stale orders, affirmative and negative obligations, pre-trade transparency, post-trade transparency, investment strategies, safeguards, equity markets, waivers, dark pools, equity investors, pre-trade transparency waivers, order stubs, alternative trading systems, ATSs, indications of interest, IOIs, actionable IOIs, block sized trades, daily trading volume threshold, order-slicing methodologies, price discovery, post-trade reporting proposals, depositary receipts, exchange traded funds, certificates, UCITS, non-EU markets, non-EU investment firms, MiFID framework directive, non-equity instruments, comprehensive price date, comprehensive notional data, regulatory transparency thresholds, data consolidation, approved publication arrangements, APAs, European Consolidated Tape, Consolidated Tape, Congress, National Market System, composite quotation system, consolidated transaction reporting system, quotations, Consolidated Tape Association, opaque market centers, sharp shoot, order flow, US Securities Industry Automation Corporation, national best bid and offer, depth of market quotations, reporting protocols, third party information vendors, Securities Industry and Financial Markets Association, NetCoalition, Yahoo Inc, Google, Bloomberg L.P., depth-of-market fees, NetCoalition v. Securities and Exchange Commission, core date, consolidated core data, CQ plan, position-level data, harmonised position information, reasonable threshold, nexus, trader ID, transaction report, confidentiality obligation, client identifier, statutory obligation, OTC contract, trade repository, summary disclosure, ex-post disclosure, ex-ante disclosure, conflicts of interest, title transfer collateral arrangement, retail client, member states, cash balance, risk warnings, securities financing transaction, information requirements, due diligence obligations, third country regime, equivalence mechanism, strict equivalence, market disorder, systemic risk, unilateral bans, market turmoil, cost/benefit analysis, regulatory authorities, consultation papers, systemic risk grounds, CCP, capital flows, lending flows, credit flows, International Swaps and Derivatives Association, ISDA, G20, Financial Stability Board, European Market Infrastructure Regulation, EMIR, sovereign CDS, European Commission's report of Sovereign CDS, credit default swaps, CDS market, hedgers, hard position limits, physical commodity markets, market manipulation, position management, mechanical imposition, commodity derivatives, CESR, UK Treasury and Financial Services Authority, price movement, derivatives position, Disclosure, reporting obligations, transparency directive, security-based derivatives, European Commission Request for Additional Information in relation to the Review of MiFID, volatility, non-hedging, aggregate open interest/notional amount, reporting regimes, contract, market data,
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