MFA Comment Letters

Topic: exchanges

MFA Response to FSA Discussion Paper on Implementation of the AIFMD03.23.12


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Topics: FSA Discussion Paper "Implementation of the Alternative Investment Fund Managers Directive" Financial Services Authority, FSA, Alternative Investment Fund Managers Directive, AIFMD, non-EU AIFM, Member State competent authorities, letter-box entity, MiFID, MiFID firm, AIFMD firm, retail customers, professional investors, remuneration provisions, CRD3 framework, functional and hierarchal independence, risk management, internationally coordinated approach to reporting, European Securities and Markets Authority, ESMA, single AIFM, family relationship, family investment vehicle, UK AIFM, preferential treatment, side letters, retail consumers, FSA Principles for Business, FCA, UCITS Directive, retail investors, EU Passport, FCA Approach Document, conflicts of interest, SYSC 10 of the FSA Handbook, remuneration guidelines, MiFID portfolio managers, tier 4 firm, FSA Remuneration Code, compliance function, audit function, proportionality principle, regulatory requirements, regulatory risks, chief compliance officer, functional and hierarchical separation, portfolio management, portfolio management personnel, interest alignment, qualitative risk limit, UCITS investors, institutional investors, leverage, NAV, third country, Final Advice on the AIFMD, third country managers, capital requirements, PII requirements, IPRU (INV), professional indemnity insurance, professional negligence, internally managed AIF, CAD-defined terms, valuation procedures, external valuer, net asset value, limited partnership, hedge funds, NAV per share, liquidity requirements, redemption terms, less than fully invested, risk/return profile, net assets under management, investor capital, Value at Risk, VaR methodology, European Central Bank, foreign exchange, interest rate risk, EUR denominated bonds, portfolio risk, hedging arragements, CESR Guidelines on Risk Management and the Calculation of Global Exposure and Coutnerparty Risk for UCITS, CDS, Advanced Method, QIS disclosure requirements, prime brokers, exchanges, swap data warehouses, Dodd-Frank Act, Securities and Exchange Commission, SEC, Form PF, proprietary business information, depositary, unregulated CIS, segregated account, valuation oversight duties, depositary liability, marketing, reverse solicitation process, MiFID investment services, private placement, public offers,

MFA Submits Comment Letter to CFTC on Proposed Dodd-Frank Implementation Rules for Mandatory Swap Clearing, Trade Execution, and Margin Rules11.04.11


The OTC derivatives reforms (Title VII) resulting from the Dodd-Frank Act will cause sweeping transformation of the OTC derivatives markets […]

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Topics: Commodity Futures Trading Commission CFTC, swaps, swap transaction, swap transaction compliance, clearing, trade execution, margining, margining requirements, Dodd-Frank Act, mandatory clearing, Rulemaking, Gary Gensler, central clearing, market participants, buy-side participants, end-user exemptions, product definition rules, Securities and Exchange Commission, SEC, security-based swaps, swap dealer, Security-Based Swap Dealer, Major Swap Participant, Major Security-Based Swap Participant, collateral, full-scale clearing, uncleared swaps, liquidity, execution, Category 2 Entities, Category 1 Entities, active fund, buy-side market participants, private funds, swap execution facilities, SEF, Designated Contracts Markets, DCMs, real-time reporting, swap data, Regulators, derivatives clearing organization, futures commission merchants, FCM, non-dealer market participants, clearing mandate, G20, OTC derivatives, over-the-counter derivatives, exchanges, electronic platform, central counterparties, CCP, federal register, class of swaps, voluntary clearing, Category 3 Entities, Scott O'Malia, compliance schedules, compliance date, made available for trading, partial tear-ups, novations, third-party subaccount, non-MSP counterparties, interest rate swaps, broad-based index credit default swaps, commodity swaps, systemic risk, real-time clearing, cost-benefit analysis, price distortion, bilateral execution, execution venue, listing, security-based swap SEF, Category 4 Entities, trading documentation, phased implementation, transparency, prudential regulators, variation margin, netting, counterparties,

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,