MFA Comment Letters

Topic: Gary Gensler

MFA Coalition Submits Joint Letter to SEC and CFTC on CDS Customer Portfolio Margining05.10.13


MFA, the American Council of Life Insurers (ACLI), and the Alternative Investment Management Association (AIMA) (collectively, the “Associations”) submitted a […]

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Topics: ACLI American Council of Life Insurers, AIMA, Alternative Investment Management Association, Mary Jo White, Gary Gensler, SEC, CFTC, Securities and Exchange Commission, Commodity Futures Trading Commission, portfolio margining, clearing, ICE Clear Credit LLC, security-based swaps, swaps, credit default swaps, CDS, buy-side participants, sell-side firms, margin, central clearing, Investor Protection, market efficiency, derivatives, hedging, FCM, futures commission merchants, broker-dealer, single-name CDS, economic barriers, systemic risk, counterparty credit risk, credit risk, offsetting position, collateral, price distortion, broad-based indices, narrow-based index credit default swap, initial margin, initial margin requirements, margin requirements, registered clearing agencies, derivatives clearing organization, DCO, clearinghouse, capital, segregation, clearing agency, self-clearing members, dealers, Financial Industry Regulatory Authority, FINRA, end-users, regulatory framework, interconnectedness, ICE Trust, Federal Reserve Bank of New York, settlement, New York State Banking Department, risk management, variation margin, long-short strategies, interest rate swaps, market participants, clearing mandate, master netting agreements, voluntary clearing, backloading, iTraxx Europe, liquidity, liquidity requirements, tri-party segregation arrangements, custody bank, institutional custodian, excess margin, legal segregation with operation commingling, LSOC, LSOC with excess, directional portfolio, insolvency, equity markets, arbitrage, S&P 500, price competition, direct clearing members, DCM, liquidation, proprietary strategies, volatility, net margin, margining, straight-through processing, counterparty risk, speculative position, Options Clearing Corporation, OCC, short straddles, capital formation,

MFA and AIMA Submit Joint Letter to CFTC on Further Proposed Cross-Border Guidance02.06.13


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (CFTC) on its “Further Proposed Guidance […]

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Topics: Commodity Futures Trading Commission CFTC, Cross-Border, swaps, duplicative regulation, Alternative Investment Management Association, AIMA, Dodd-Frank Act, prime brokers, hedge fund managers, U.S. person, interpretive guidance, market participants, Corporation, partnership, Limited Liability Company, LLC, Trust, joint-stock company, direct or indirect ownership, commodity pool, pooled accounts, collective investment vehicles, commodity pool operator, CPO, pension, estate, income tax, principal place of business test, investment manager, limited liability partnership, LLP, investment fund, ownership test, derivatives, OTC derivatives, over-the-counter derivatives, OTC derivatives market, international harmonization of regulations, regulatory framework, swap dealer, Major Swap Participant, msp, Securities and Exchange Commission, SEC, European Securities and Markets Authority, ESMA, European Parliament, Council of the European Union, central counterparty, CCP, trade repositories, mandatory clearing requirements, clearing, central clearing, systemic risk, Gary Gensler, Mary Schapiro, OTC derivatives reform, CPPSS-IOSCO, IOSCO, International Organization of Securities Commissions, European Union, EU, Hong Kong Monetary Authority, Hong Kong, Monetary Authority of Singapore, Singapore, MAS, foreign regulators, Dealer, buy-side market participants, registration, adviser registration, Office of the Comptroller of the Currency, OCC, majority ownership, Look Through, fund of funds, listed entity, Form CPO-PQR, de minimis, commodities, phase-in period, execution, G20, G20 commitments, transparency,

MFA Submits Comments to the Monetary Authority of Singapore on Proposed Regulations on OTC Derivatives03.26.12


MFA submitted a comment letter to the Monetary Authority of Singapore (MAS) in response to its Consultation Paper on Proposed […]

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Topics: Monetary Authority of Singapore MAS, OTC derivatives, over-the-counter derivatives, Consultation Paper on Proposed Regulation of OTC Derivatives, G20, OTC derivatives market, systemic risk, efficient capital flows, mandary clearing, clearing, bilateral market, risk management, derivatives transactions, trading mandate, liquid and standardized transactions, client access to clearing, clearing arrangements, margin methodologies, straight-through processing, central clearing, Commodity Futures Trading Commission, CFTC, Gary Gensler, Securities and Exchange Commission, Mary Schapiro, market participants, central counterparty, CCP, average notional value, clearing threshold, buy-side clearing, U.S. Federal Reserve Bank of New York, Dodd-Frank Wall Street Reform and Consumer Protection Act, Dodd-Frank Act, backloading, Financial Stability Board, FSB, international harmonization of regulations, swaps, European Union, EU, European Commission, ESMA, legal entity identifiers, confidentiality, transaction data, counterparty identification, customized and proprietary investment strategies, intellectual property, International Organization of Securities Commissions, IOSCO, foreign regulator, financial entities, non-financial entities, Singapore, Form PF, margin requirements, netting, trading costs, aggregate counterparty credit risk, settlement risk, commercial banks, dealers, money changers, registered insurers, non-centrally cleared derivatives transactions, margin determinations, liquidation horizons, fragmentation of liquidity, clearing house, counterparty risk, recognized clearing houses, clearing facilities, real-time processing, barriers to entry, non-dealer client representation, risk committees, G20 commitments, regulatory regime, duplicative regulation, U.S. Senate Committee on Agriculture Nutrition and Forestry, trade repositories, Securities and Futures Commission, Honk Kong Monetary Authority,

MFA, SIFMA and GFXD Submit Joint Letter to the CFTC with Proposed Safe Harbor for the ECP Definition01.19.12


On January 19, MFA, SIFMA, and GFXD submitted a joint letter to the CFTC with a proposed safe harbor from […]

MFA Submits Comment Letter to CFTC on Proposed Dodd-Frank Implementation Rules for Mandatory Swap Clearing, Trade Execution, and Margin Rules11.04.11


The OTC derivatives reforms (Title VII) resulting from the Dodd-Frank Act will cause sweeping transformation of the OTC derivatives markets […]

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Topics: Commodity Futures Trading Commission CFTC, swaps, swap transaction, swap transaction compliance, clearing, trade execution, margining, margining requirements, Dodd-Frank Act, mandatory clearing, Rulemaking, Gary Gensler, central clearing, market participants, buy-side participants, end-user exemptions, product definition rules, Securities and Exchange Commission, SEC, security-based swaps, swap dealer, Security-Based Swap Dealer, Major Swap Participant, Major Security-Based Swap Participant, collateral, full-scale clearing, uncleared swaps, liquidity, execution, Category 2 Entities, Category 1 Entities, active fund, buy-side market participants, private funds, swap execution facilities, SEF, Designated Contracts Markets, DCMs, real-time reporting, swap data, Regulators, derivatives clearing organization, futures commission merchants, FCM, non-dealer market participants, clearing mandate, G20, OTC derivatives, over-the-counter derivatives, exchanges, electronic platform, central counterparties, CCP, federal register, class of swaps, voluntary clearing, Category 3 Entities, Scott O'Malia, compliance schedules, compliance date, made available for trading, partial tear-ups, novations, third-party subaccount, non-MSP counterparties, interest rate swaps, broad-based index credit default swaps, commodity swaps, systemic risk, real-time clearing, cost-benefit analysis, price distortion, bilateral execution, execution venue, listing, security-based swap SEF, Category 4 Entities, trading documentation, phased implementation, transparency, prudential regulators, variation margin, netting, counterparties,