MFA Comment Letters

Topic: financial counterparty

Comment Letter to the SEC and CFTC on Definitions of “Swap Dealer, Security-Based Swap Dealer (together, SDs), Major Swap Participant, Major Security-Based Swap Participant (together MSPs) and Eligible Contract Participant (ECP)02.22.11


MFA submitted a comment letter to the SEC and CFTC on their joint proposed rule to further define swap dealer, […]

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Topics: Commodity Futures Trading Commission Securities Exchange Commission, CFTC, SEC, Swaps dealer, SD, Security-Based Swap Dealer, Major Swap Participant, Major Security-Based Swap Participant, msp, security-based swaps, market activity, market growth, systemic risk, United States financial markets, potential future exposure test, systemically important, MSP thresholds, Dealer, end-users, default risk, risk-mitigating tools, hedge fund managers, potential future exposure calculation, over-collateralization, current uncollateralized outward exposure test, independent amount of collateral, initial margin, mark-to-market exposure, ISDA master agreements, daily variation margin calls, valuation of collateral, future exposure discount, centrally cleared positions, central clearing, clearing member defaults, clearinghouse, variation margin, daily volatility, risk mutualization, discount factor, independent variable, tools of credit protection, reproducible test, credit default swaps, CDS, index CDS, unpaid premiums, portfolio risk, fixed downside risk, interest rate swap, LIBOR, swap rate, market-standard discount rate, CDS protection, index reference entity, volatility, jump-to-default risk, single-name CDS, risk factor multiplier, high yield credit swaps, investment-grade credit swaps, credit spreads, credit ratings, investment grade, non-investment grade, margin methodologies, bank capital standards, Chicago mercantile exchange, CME, Financial Industry Regulatory Authority Inc., FINRA, multiplier, spread bank designation, swap underlier, swaptions, options on a swap, physically settled swaptions, cash settled swaptions, option expiration date, Form PF, delta weighting, Financial Stability Oversight Council, large private fund, smaller private fund, Form PQR, MSP definitions, Proposed Form PF section 1b, question 11, question 27, proposed form PF section 2(a), question 38, proposed form PF section 3, question 47, proposed form PF section 4, question 68, proposed Form PQR, schedule B, question 5, substantial counterparty exposure, MSP test, substantial position, undiversified market participant, counterparty exposure, systemically important financial institution, commercial hedging, index derivatives, commercial loans, mitigating commercial risk, threshold levels, dealers, uncollateralized exposure, potential systemic risk impact, inflation, upward adjustment, U.S. banking system, highly leveraged, liabilities to equity, asset mix, liquidity, liquidity rights, capital markets, secured debt, unsecured debt, short-term leverage, overnight borrowing, short-term financing, highly liquid assets, US Treasuries, longer-term leverage, term borrowings, risk factor multipliers, high-grade corporate securities, FSOC, hedge funds, eligible contract participant, ECP, non-ECP, financial counterparty, traditional commodity pool, Retail Forex Pool, SD obligations, retail cash, currency based institutions, limited purpose designations, minimum duration of status, quarters, deregistration period, reevaluation period, abnormal price movement, applicable MSP thresholds, master-feeder fund, feeder fund, trading entity, MSP determination, Senator Hagan, Senator Lincoln, creditworthiness, know your counterparty requirements, daily mark requirements, trade verification, acknowledgment requirements, fund domicile, manager domicile, reference entity domicile, market location, underlying instrument, counterparty domicile, US entities, non-US entities, non-US domiciled fund, non-US securities, non-U.S. market, offshore fund, non-U.S. regulators.,

MFAs Response to Proposed Regulation of OTC Derivatives, Central Counterparties and Trade Repositories11.11.10


MFAs Response to Proposed Regulation of OTC Derivatives, Central Counterparties and Trade Repositories

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Topics: Proposed Regulation of OTC Derivatives European Union, central clearing, derivatives market, European Commission, Council on OTC Derivatives, Central Counterparties and Trade Repositories, Over-the-counter Derivative Market, OTC, Risk Management Activities, Market Particpants, Class of Derivatives, clearing, Manadatory Clearing Obligation, interest rate swaps, IRS, central counterparties, CCPs, European Securities and Markets Authority, ESMA, European Parliament, Council of Ministers, financial counterparty, Alternative Investment Fund, investment manager, Derivative Contracts, clearing obligation, operational risk, counterparty risk, transparency, competition, Top Down, Bottom Up, Determination Process, Trade Reporting Obligations, risk mitigation techniques, Segregated Exchange of Collateral, Proportionate Holding of Capital, capital requirements, Collateral Posting, Segregate and Exchange Margin, Hold Capital, initial margin, variation margin, Mark-to-Market Changes, Follow-on Effects, Market Exposure, Maximum Time Lag for Confirmation, systemic risk, third country CCPs, Non-European Countries, non-discriminatory access, Interoperability, Equivalency Test, Cross-Border Efficiency and Consistency, risk committees, Effective Supervision, Co-Operation Arrangement, Particpation Requirements, Admissable Clearing Members, Standard Capital Requirements, segregation, portability, Protection of Client Positions and Collateral, U.S. Treasury and U.S. Commodity Futures Trading Commission, U.S. House of Representatives Committee on Financial Services, U.K. House of Lords, European Policymakers, Insolvency Regimes, Unwinding Costs, Swiftly Collapse Offsetting Positions, Optimal Netting, Derivative Contract's Lifecycle, client collateral, Risk Profiles, Financial Strength, default, Trigger, Shortfall, Unmanageable Risk, capital formation, Investment Policy, Highly Liquid Collateral, Minimal Credit Risk, Highly Liquid Financial Instruments, market risk, credit risk, Highly Liquid, Denominated in G7 Currencies, Government Securities, default procedures, confidentiality, trade repositories, competent authorities, reasonable threshold, nexus, Coordination with Third-Country Regulators, Central Banks,
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