MFA Comment Letters

Topic: Federal Trade Commission

MFA Letter to FTC on Prohibition of Energy Market Manipulation Rule05.20.09


MFA jointly with FIA, CME Group, ICE and NFA submitted a letter to the Federal Trade Commission regarding its “Prohibition […]

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Topics: Federal Trade Commission FTC, Market Manipulation Rulemaking, futures group, Part 317, anti-manipulation protections, non-futures, wholesale markets, crude oil, gasoline, commodities, Manipulation, fraud proscriptions, Commodity Futures Trade Commission, CFTC, petroleum distillates, exclusive jurisidiction provision, safe harbor, federal register, exclusive jurisdiction provision, price discovery, forward market business activities, regulatory, CEA, anti-manipulation system, false reports, commodity prices, resource limitations, congressional grant, energy markets, John M. Damgard, Futures Industry Association, FIA, Jerrold E. Salzman, CME Group Inc., Thomas W. Sexton, National Futures Association, NFA, Jeffrey Sprecher, IntercontinentalExchange, ICE, Donald S. Clark, Advanced Notice of Proposed Rulemaking, wholesale purchase, options trading, energy futures, futures exchange, Chciago Mercantile Exchange Inc., Board of Trade of the City of Chicago, Inc., CBOT, new York Mercantile Exchange Inc., NYMEX, Commodity Exchange, COMEX, ICE Futures U.S., New York Board of Trade, ICE Futures of Europe, ICE Futures Canada, Winnipeg Commodity Exchange, over-the-counter energy trading platform, commercial market, limited-purpose national securities association, customer protection, merchants, brokers, commodity pool operators, commodity trading advisors, registered account executives, sugar, corn, ethanol, price effects requirements, compliance burden, U.S. Court of Appeals for the Seventh Circuit, Board of Trade of City of Chicago v. SEC, 677 F.2d 1137 (7th Cir. 1982), Chicago Mercantile Exch. v. SEC, 883 F.2d 537 (7th Cir. 1989), Board of Trade of City of Chicago v. SEC 677 F.2d 1137, 1145 (7th Cir. 1982), FTC v. Roberts, 276 F.3d 583 (D.C. Cir. 2001), 276 F.3d at 592, chain of precedent, 276 F.3d at 591, SEC vs. Hopper, corporate disclosures, US vs. Reliant Energy Services, 420 F Supp.2d 1043 (N.D. Cal. 2006), exclusive regulatory authority, Federal Energy Regulatory Commission, FERC, instruments, accounts, Ken Roberts Co. v. FTC, No. 01-1772, 537 U.S. 820, 2002 WL 32135703, speculative limits, Energy Department, DOE, Environmental Protection Agency, EPA, emissions credit, Agriculture Department, USDA, Williamson v. United States, 512 U.S. 594, Trichilo v. Sec'y of Health & Human Servs., 823 F.2d 702, 706 (2d Cir. 1987), SEC v. American Commodity Exch., 546 F.2d 1361, International Trading Ltd. v. Bell, 556 S.W.2d 420 (Ark. 1977), Clayton Brokerage Co. v. Mouer, 531 S.W.2d 805 (Tex. 1975), Minnesota v. Coin Wholesalers, 250 N.W.2d 583 (Minn. 1976), Amaranth, statutory authority, non-petroleum based commodities, agricultural feed-stocks, price artificiality, contract markets, intermediaries, agents, counterparties, contractual privity, contradictory requirements, United States Congress, 2006 WL 778640 (S.D. Tex. March 24 2006),

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,
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