MFA Comment Letters

Topic: FIA

MFA Submits Letter to ESMA on Straight-Through-Processing08.05.12


On August 5, MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) to advocate for the […]

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Topics: ESMA European Securities and Markets Authority, OTC derivatives, CCP, trade repositories, straight-through processing, regulatory technical standards, EMIR, over-the-counter derivatives, derivatives, European Parliament, Council of the European Union, OTC derivatives transactions, central counterparty, systemic risk, counterparty credit risk, credit risk, market access, efficiency, operational market processes, clearing, execution, executing counterparty, market participants, clearing obligation, documentation, clearing member, interest rate swap, credit default swap, CDS, CME, Chicago mercantile exchange, alternative liquidity providers, liquidity, risk, electronic trading, bilateral derivatives transactions, bilateral master agreements, risk management, real-time processing, Commodity Futures Trading Commission, CFTC, Designated Contract Market, DCM, Swap Execution Facility, SEF, execution platform, Allocations, cost-benefit analysis, European Union, EU, ESMA Task Forces, transparency, OTC Derivatives Task Force, CCP Requirements Task Force, Trade Repositories Task Force, derivatives transactions, international harmonization of regulations, Financial Stability Board, FSB, European Commission, delegated acts, customer clearing documentation, directive, due diligence, operational risk, Court of Justice of the European Union, Continental Cans, EU Member State, Commission v. Council ERTA, financial stability, Christopher Seagon v. Deko Marty Belgium NV, clearing agreement, financial system, United States, Dodd-Frank Act, real-time acceptance, competition, settlement, liquidity fragmentation, central limit order books, International Swaps and Dealers Association, ISDA, bid-ask spread, limit check, trading venues, credit intermediation, derivatives markets, bilateral risk management, volatility, derivatives clearing organization, DCO, swap dealer, Major Swap Participant, dealer-to-dealer clearing, dealer-to-customer platforms, mandatory clearing, clearinghouse, bilateral credit agreement, bilateral market, competitive liquidity, block transactions, investment managers, breakage, Futures Industry Association, FIA, trading desk, anti-competitive effects, ICE energy swaps, ICE Clear Credit LLC, LCH Clearnet, clearing acceptance process, trilateral documentation, designation notice, Managed Funds Association, bundled trade, futures, futures market, credit limit order bookc, credit limit, interconnectedness, dealers, real economy, pension fund, endowments, institutional investors, Liquidity Providers, trilateral clearing agreements, energy derivatives, technical standards, voice execution, matched transactions, direct clearing members, credit limits, risk-based, latency, transaction capture facility, anti-competitive restrictions, aggregate limit, underlying clients,

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,

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,

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),