MFA Comment Letters

Topic: Federal Reserve Board

MFA Submits Letter to SEC on Proposed Capital, Margin, and Segregation Rules02.22.13


MFA submitted a comment letter to the Securities and Exchange Commission (SEC) on its proposed rules on “Capital, Margin, and […]

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Topics: Securities and Exchange Commission SEC, margin, capital, segregation, Security-Based Swap Dealer, Major Security-Based Swap Participant, capital requirements, broker-dealer, risk, security-based swaps, customer collateral, Dodd-Frank Act, CFTC, Commodity Futures Trading Commission, Private Funds Managers, Investor Protection, regulation, international regulatory standards, efficiency, capital formation, liquidity, collateral, margin requirements, market participants, variation margin, netting, margining, Financial Industry Regulatory Authority, FINRA, international harmonization of regulations, regulatory arbitrage, federal register, bilateral exchange of variation margin, best practices, counterparty risk, systemic risk, risk management, portfolio margining, securities, cross-product master netting agreements, initial margin, financial system, asset class, counterparties, prudential regulators, leverage, derivatives, tri-party custodial arrangements, customer protection, omnibus segregation, default, fellow customer risk, legal segregation with operation commingling, LSOC, swap dealers, Major Swap Participant, Individual Segregation, buy-side firms, non-commercial end-users, hedge funds, credit risk, capital inefficiency, transparency, Basel Committee on Banking Supervision, International Organization of Securities Commissions, IOSCO, Working Group on Margining Requirements, central clearing, compliance, registered clearing agencies, mandatory clearing, compliance date, two-way margining, reform, collateral management, asymmetrical initial margin exchange, pension, endowments, university endowment, financial crisis, "too big to fail, too interconnected to fail, American International Group, AIG, House Committee on Financial Services, Ben Bernanke, Federal Reserve Board, 111th Congress, financial contagion, financial institutions, asymmetry, portfolio reconciliation, portfolio compression, Swap Trading Relationship Documentation, swap dealer, collateral management stystems, trading costs, complexity, settlement risk, credit default swap, CDS, OTC derivatives, forwards, repurchase agreements, Value at Risk, VaR, financial instrument, cross-margining, Options Clearing Corporation, Chicago Mercantile Exchange Holdings Inc., New York Portfolio Clearing LLC, LCH.Clearnet Ltd., customer replicability, proprietary information, reconciliation, market risk, haircuts, Cash Flow, pro-cyclical effects, creditworthiness, multiplier, customized risk management tools, sell-side firms, liquidation time horizon, product type, market practice, ISDA, U.S. dollar, settlement, money market instruments, eligible collateral, capital charge, Lehman Brothers, bankruptcy, bankruptcy estate, third-party custody arrangement, enhanced protections, Notice of Exclusive Control, Investment Company Institute, ICI, White Paper, Securities Industry and Financial Markets Association, SIFMA, liquidation, Federal Reserve Bank of New York, tentative net capital, dealers, Eric Chern, Chicago Trading Company, \, operational risk, Security-Based Swap Transactions, Darrell Duffie, Federal Reserve Bank of New York Staff Report No. 424, ICE Clear Europe Limited, segregation model, DCO, derivatives clearing organization, portability, insolvency, out-of-the-money, operational and legal commingling, default segregation model, MF Global Inc., Peregrine Financial Group, Fraud, investment risk, Russell Wasendorf, accounting, operational costs, Broker, Dealer, ISDA Margin Survey 2012, European Commission, European Parliament, Council of the European Union, central counterparty, CCP, trade repositories, commodity broker, Bart Chilton, Division of Clearing and Intermediary Oversight, Robert Wasserman, independent third party custodian, state bank regulator, state and federal laws,

MFA Comment Letter to the Committee of European Securities Regulators in Response to its Call for Evidence on Mutual Recognition with Non-European Union Jurisdictions09.04.09


MFA submitted a letter to the Committee of European Securities Regulators today in response to its Call for Evidence on mutual […]

MFA Letter to Senate Republican Capital Markets Task Force Regarding United States Capital Markets Competitiveness in the Global Financial Services Marketplace02.29.08


MFA submits a comment letter to the Senate Republican Capital Markets Task Force in response to the Task Force’s request […]

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Topics: Senate Republican Capital Markets Task Force United States Congress, capital markets, U.S. Capital Markets, global financial system, regulatory regime, tax, capital formation, capital efficiencies, financial regulatory system, principles-based regulation, Securities and Exchange Commission, SEC, regulation, non-U.S. investors, capital, hedge funds, venture capital funds, oil and gas partnerships, Strategy and Financial Innovation, Investor Protection, Financial Services Roundtable, Blue Print for U.S. Financial Competitiveness, Commodity Futures Trading Commission, CFTC, safe harbor, exchanges, market crisis, market participants, duplicative regulation, public commodity pools, National Futures Association, NFA, Financial Industry Regulatory Authority, FINRA, commodity futures markets, energy commodities, Federal Energy Regulatory Commission, FERC, natural gas futures market, Federal Trade Commission, financial services industry, President's Working Group on Financial Markets, PWG, Department of the Treasury, Secretary of the Treasury, Federal Reserve Board, assets under management, investment advisers, retail investors, prudential regulators, Henry Paulson, Office of Compliance Inspections and Examinations, OCIE, Economic Club of New York, no-action letters, General Solicitation, General Advertising, transparency, Cross-Border, U.S. immigration policies, skilled non-U.S. professional workers, H-1B visa, student visa, harmonization, generally accepted accounting principles, GAAP, International Financial Reporting Standards, IFRS, mutual recognition, Canada, Enron Corporation, Cendant, Financial Services Forum, United Kingdom, European Union, EU, chilling effect, equity markets,

MFA Comment Letter to Canadian Securities Administrators on Registration Reform06.29.07


MFA submits comments and attachment to the Canadian Securities Administrators on Canadian registration reform.

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Topics: British Columbia Securities Commission Alberta Securities Commission, Saskatchewan Financial Services Commission, Manitoba Securities Commission, Ontario Securities Commission, Autorite des Marches Financiers, New Brunswick Securities Commission, Register of Securities Prince Edward Island, Nova Scotia Securities Commission, Superintendent of Securities Newfoundland and Labrador, Register of Securities Northwest Territories, Register of Securities Yukon Territory, Register of Securities Nunavut, Proposed National Instrument 31-103, registration requirements, global alternative investment industry, hedge funds, fund of funds, managed futures funds, policymakers, absolute return strategies, hedge fund industry, regulatory authorities, educational outreach, alternative investment history, Commodity Futures Trading Commission, CFTC, Federal Reserve Board, Department of the Treasury, Canadian Securities Administrators', CSA, global financial marketplace, President's Working Group on Financial Markets, PWG, private pools of capital, capital markets, financial markets, liquidity, price efficiency, risk distribution, alternative investment opportunities, capital, funds, Canada, (NI31-103), alternative investment vehicles, regulation, privately offered fund, professional investment management for hedge fund managers, defined term, U.S. federal securities laws, investment company, venture capital, private equity, leveraged buyout, oil and gas, real estate funds, hedging, distressed, financing, large activist posistions, risk-adjusted performance, private equity funds, assets under management, AUM, Non-Canadian Hedge Fund Securities, capital raising, retirement plans, pension plans, exposure, international capital markets, National instrument 45-106, Prospects and Registration Exemptions, Labrador, non-resident dealers, limited market dealers, dealer registration requirements, Non-Ontario Regime, securities, Regulatory Authority, offering memorandum, offering document, Ontario Regime, prospectus exemption, disclosure obligations, dealer registration exemption, market intermediaries, flow-through analysis, adviser registration, commodity futures, non-resident exemptions, Commodity futures act, Administrative Costs, Fraud, international portfolio manager, international investment fund manager, advisers, fund units, Ontario registered dealer, registered broker-dealer, broker-dealer, exempt market trades, accredited investors, sophisticated investors, fund-of-funds, financial institutions, hedge fund consultant, private placement, White Paper, financial eligibility, standards, pooled investment products, investment sophistication, natural persons, net worth threshold, annual income threshold, private investment vehicles, accredited natural person, income tests for inflation, grandfather provision, dealer registrayion exemption, offshore investment vehicles, United Kingdom, European Union, EU, well-developed capital markets, regulatory regimes,
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