MFA Comment Letters

Topic: extraterritorial application of EMIR

MFA Submits Letter to ESMA on Draft Technical Standards on OTC Derivatives08.05.12


MFA submitted a comment letter to the European Securities and Markets Authority (“ESMA”) in response to its Consultation Paper on “Draft Technical […]

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Topics: European Securities and Markets Authority ESMA, over-the-counter derivatives, OTC derivatives, CCP, trade repositories, European Parliament, Council of the European Union, OTC derivatives transactions, central counterparty, EMIR, central clearing, systemic risk, transparency, collateral, segregation, regulatory technical standards, straight-through processing, OTC derivatives market, market participants, Dealer, portability, client protections, contractual relationship, clearing member, CPSS-IOSCO, CPSS-IOSCO standards, CCP governing bodies, margin valuation, margin, risk management, risk management framework, conflicts of interest, fiduciary duty, International Organization of Securities Commissions, IOSCO, proprietary trading tools, risk committee, derivatives contracts, derivatives, risk profile, interlocking governance arrangements, trading venues, Commodity Futures Trading Commission, CFTC, Securities and Exchange Commission, SEC, internal controls, over-collateralization, in-the-money swap, "delta" hedge, swaps, credit default swap, CDS, negative correlation, capital, trading costs, credit risk, indirect clearing, non-linear products, Europe, European Union, EU, administrator, omnibus account, default, principal basis, agency basis, gross basis, net basis, LCH Clearnet, indirect client, direct client, close-out, extraterritorial application of EMIR, extraterritoriality, risk mitigation, Dodd-Frank Wall Street Reform and Consumer Protection Act, Asia, regulatory arbitrage, Regulators, counterparty risk, duplicative regulation, mutual recognition, third country regime, interpretive guidance, Cross-Border, index, foreign exchange, Euro, currency, interest rate derivatives, EU Member State, non-cleared OTC derivatives, compliance, default fund, portfolio reconciliation, portfolio compression, self-regulatory organization, SRO, swap dealers, major swap participants, Derivative Contracts, bilateral non-cleared OTC derivatives transactions, execution, hedging, upfront payment, floating rate payment, coupon, maturity, bespoke non-cleared trades, security-based swaps, debt-security based swaps, total return swaps, settlement prices, Proprietary Trading Strategy, public disclosure, confidence interval, margin requirements, financial instrument, posted collateral, interest rate swaps, Stan Ivanov, Lee Underwood, variation margin, initial margin, Basel Committee on Banking Supervision, Basel III, liquidation horizons, bilateral counterparty credit risk, netting, transaction fees, liquidity fragmentation, affiliated market participants, money market instruments, credit institutions, stress testing, back testing,

MFA Submits Comments to ESMA in Response to Draft Technical Standards on OTC Derivatives, CCPs and Trade Repositories03.19.12


MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) in response to its Discussion Paper on […]

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Topics: OTC derivatives European Securities and Markets Authority, ESMA, EMIR, European Union, EU, over-the-counter derivatives, central clearing, counterparty and operational risk, market oversight, market integrity, systemic risk, derivatives market, OTC derivatives market, ESMA Discussion Paper on Draft Technical Stanards for the Regulation on OTC Derivatives CCPs and Trade Repositories, central counterparty, CCP, risk management expertise, straight-through processing, CCPs governance structure, clearing, competitive execution, Commodity Futures Trading Commission, CFTC, execution platform, alternative liquidity providers, electronic trading, real-time processing, international harmonization of regulations, client clearing models, third country counterparities, clearing obligation, extraterritorial application of EMIR, fund domicile, manager domicile, reference entity domicile, market location, reference security, underlying instrument, third country entities, principal of business, foreign exchange derivatives, interest rate derivatives, Euro, EU member currency, settlement currency, notional amount, indirect contractual arrangements, Cayman Islands, American Depository Receipt, ADR, Hong Kong, segregation, portability, indirect clearing models, guarantor, credit intermediary, execution documentation, credit intermediation, FIA-ISDA Cleared Derivatives Execution Agreement, futures commission merchant, FCM, swap dealer, SD, sublimit, Futures Industry Association, FIA, International Swap Derivatives Association, ISDA, clearing member, counterparty credit risk, indirect clearing, executing counterparty, back-to-back arrangements, trade acknowledgment, Dodd-Frank Act, Securities and Exchange Commission, SEC, security-based swaps, bespoke and customized transactions, electronically processed, CCP governance arragements, chief risk officer, chief technology officer, chief compliance officer, sound governance requirements, non-dealer representatives, risk committees, CCP committee, CCP Board, conflicts of interest, disclosure requirements, clients, record keeping, privacy and confidentiality of information, confidentiality agreements, CCP's margin models, confidence interval, liquidation period, lookback period, margin levels, margin requirements, technical standards, stress tesing, back testing, CCP data, non-default clearing members, clearing members, default, aggregation, public dissemination of information, transaction volumes, reasonably liquid traded instruments, confidentiality of counterparty identities, disclosure thresholds,
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