MFA Comment Letters

Topic: FCMs

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

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 to the CFTC in Response to its Request for Comments on Position Limits for Derivatives03.28.11


MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains […]

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Topics: CFTC Commodity Futures Trading Commission, position limits, derivatives, futures, option contract, swap contract, futures market, price risk, commercial participants, operating company, financial institution, energy market infrastructure, liquid price discovery, risk-shifting market, market manipulation, federal limits, crowding out provision, spot month, disaggregation relief, deliverable supply, inter-commodity spread transactions, bona fide hedger, price discovery, risk management, commodity market, annual recalculation methodology, U.S. futures exchange, delivery point, individual class rules, legacy position limits, agricultural commodities, disorderly markets, spot-month position limits, referenced contracts, aggregate spot-month position limits, swaptions, DCMs, physically delivered contracts, cash-settled contracts, conditional-spot month limit, cash position, forward position, physical commodity deliverable, aggregate all-months-combined, aggregate single-month, futures class all-months-combined, futures class single-month, swaps class all-months-combined, swaps class single-month, open interest, non-spot position limits, calendar-spread exemption, hedging transaction, cash market transaction, cash market risk, swap dealer hedge exemption, pool participant, future commission merchants, FCMs, independently controlled and managed trader, account aggregation requirements, enumerated agricultural commodities, open interest formula, position visibility, reporting requirements, offsetting positions, excessive speculation, interstate commerce, physical commodity, interest rates, stock indices, squeezes, market liquidity, global commodity, regulatory oversight, risk transfer, energy price volatility, CTFC Inter-Agency Task Force on Commodity Markets, GAO, IOSCO, IMG, UK Treasury, CME, The Economist, supply and demand, U.S. dollar, price volatility, NYMEX crude oil price, speculative investment, crude oil futures, International Organization of Securities Commission, IOSCO Technical Committee, IMF World Economic outlook, HM Treasury Global Commodities, OECD publishing, JP Morgan, long positions, hedge funds, short positions, Chicago onions, Berlin wheat, Credit Agricole, Energy Risk, University of Calgary, PKVerleger LLC, Wall St. Journal, Artificial limits, Barclays Capital, OECD Food, Jacks Study, Commission Energy Complex Report, Global Energy Management Institute, Bauer College of Business, University of Houston, House Committee on Agriculture, Pirrong Testimony, price spikes, agricultural model, metal commodity, seasonal variation, market surveillance, OTC, WTI, independently controlled accounts, independent third party, commodity trading advisors, common parent, CPO, CTA, control standard, commodity pool operator, commodity trading advisor, eligible entity, order routing arrangement, disclosure documents, non-financial entity exemption, active trading program, passive trading program, funds of funds, private equity investments, passive investors, pension plan, independent account controller exemption, asset manager, corporate enterprises, speculative trading ventures, CFTC docket no. 11-05, CFTC docket no. 08-02, pool participant exemption, equity interest, market depth, no-action relief, percentage interest, real-time basis, university endowment, liquidity provisions, application based exemption, approval based exemption, annual renewal based exemption, self-executing disaggregation, reporting obligation, surveillance, audit, enforcement, cross-ownership of traders, statement of reporting trader, benchmark contracts, NYMEX Henery Hub Natural Gas contract, commercial hedgers, inter-commodity spread exemption, arbitrage exemption, directional position, outright positions, submarket, large trader data, seasonality, annual limits, CBOT, NYBOT, KCBOT, pre-existing position exemption, significant price discovery contracts, index fund manager, class limits, rounding, hypothetical portfolios, cleared bilateral contracts, non-cleared bilateral contracts, front month position, deferred month positions, last day swaps, penultimate swaps, options, delta, financial cal spread options, physical cal spread options, physical options, HH natural gas,

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,

Comment Letter to the CFTC on Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties02.22.11


MFA submitted a comment letter to the CFTC on its proposal on Business Conduct Standards for Swap Dealers and Major […]

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