MFA Comment Letters

Topic: Hong Kong

MFA Submits Letter to Hong Kong on OTC Derivatives Reporting Rules08.17.14


MFA submitted comments to the Hong Kong Monetary Authority (HKMA) and the Securities and Futures Commission (SFC) in response to their […]

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: CFTC Commodity Futures Trading Commission, Timothy Massad, Mark Wetjen, Scott O'Malia, Sharon Bowen, J. Christopher Giancarlo, swaps, commodity pool operators, CPO, commodity trading advisors, CTA, alternative investment strategies, Dodd-Frank Act, OTC derivatives, systemic risk, transparency, central clearing, swap execution facilities, SEF, designated contract markets, DCM, regulation, package transactions, market infrastructures, recordkeeping requirements, swap data reporting, Cross-Border, central counterparties, CCP, third country, regulatory requirements, alternative investment funds, EMIR, JOBS Act, private investment vehicles, regulatory framework, hedge fund, fund of funds, private equity fund, real estate investment trust, burdensome, CPO delegation, temporary interim relief, private funds, harmonization, no-action relief, SEC, Securities and Exchange Commission, Policy Makers, customer protection, U.S. Congress, Bankruptcy Code, futures commission merchant, FCM, legal segregation with operation commingling, LSOC, market participant, MF Global Inc., Peregrine Financial Group, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, segregated account, FCM counterparty, position limits, buy-side, straight-through processing, made available for trading, MAT, inter-dealer market, anonymity, execution, proprietary trading tools, dealer-to-customer platforms, liquidity, derivatives clearing organization, DCO, Dealer, interest rate markets, swap curves, swap butterflies, invoice spreads, swaptions, Vincent A. McGonagle, exchange for related position, EFRPs, benchmark contracts, SIFMA AMG, Asset Management Group of the Securities Industry and Financial Markets Association, Division of Swap Dealer and Intermediary Oversight, Division of Market Oversight, introducing broker, assets under management, AUM, trading privileges, commodity pool, floor brokers, Alternative Investment Management Association, AIMA, swap data repository, SDR, Commodity Markets Council, alpha swap, beta swap, gamma swap, Major Swap Participant, MSPs, European Union, EU, bespoke swaps, International Swaps and Derivatives Association, ISDA, master agreement, European Commission, OTC Derivatives Regulators Group, mandatory clearing, United States, Cayman Islands, U.S. person, swap dealer, financial counterparty, commodity interests, privately offered commodity pools, Cayman Islands Monetary Authority, British Virgin Islands Financial Services Commission, Financial Conduct Authority, Hong Kong, Securities and Futures Commission, private investment funds, limited partnership, general partner, corporations, Trust, limited liability companies, public investment fund, board of directors, chilling effect, NFA, National Futures Association, due diligence, compliance, registered investment adviser, President Obama, Obama Administration, U.S. Department of the Treasury, quarterly account statements, service providers, illiquid assets, Form PF, Form CPO-PQR, Form CTA-PR, custody rules, generally accepted accounting principles, GAAP, Form PQR, haircuts, Committee of Payment and Settlement Systems, International Organization of Securities Commissions, IOSCO, Financial Stability Board, FSB, risk management, initial margin, variation margin, loss allocation, Full Physical Segregation, customer collateral, collateral, insolvency, cleared swaps, hedgers, short, price discovery, spot-month position limits, physically settled, cash-settled contracts, natural gas, gold, silver, owned entities, passive ownership, exemptive relief, speculation, aggregation,

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 on Hong Kong Consultation on Electronic Trading09.23.12


On September 23, MFA submitted comments to the Hong Kong Securities and Futures Commission on its consultation paper on the […]

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


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

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Topics: CFTC Commodity Futures Trading Commission, interpretive guidance, swaps, Alternative Investment Management Association, AIMA, financial crisis, over-the-counter derivatives, OTC derivatives, OTC derivatives market, hedge fund industry, fund of funds, hedge fund managers, prime brokers, hedge fund administrator, market participants, non-U.S. market participants, regulatory requirements, commodity pool, pooled accounts, collective investment vehicles, non-U.S. investment fund, Securities and Exchange Commission, SEC, international harmonization of regulations, regulatory framework, duplicative regulation, transaction cost, compliance costs, U.S. person, non-U.S. persons, derivatives, derivatives markets, Corporation, partnership, limited liability companies, joint-stock company, fund, pension plans, estate, Trust, income tax, Jill Sommers, Scott O'Malia, cost-benefit analysis, market impact, third country, European Securities and Markets Authority, ESMA, direct or indirect ownership, Look Through, shareholders, listed entity, foreign banks, banks, dealers, commodity pool operator, CPO, Form CPO-PQR, financial stability, financial system, chief compliance officer, risk management, swap data recordkeeping, swap data reporting, commodity swaps, clearing, swaps processing, margining, segregation, uncleared swaps, execution, portfolio reconciliation, real-time public reporting, trade confirmations, Business Conduct Standards, qualified eligible person, accredited investors, general partnerships, registration, CPO registration requirements, counterparties, swap dealer, major swap participants, MSPs, swap data repository, sell-side firms, buy-side firms, entity-level requirement, reporting party, comment letter, transaction-level requirements, majority ownership, G20, G20 commitments, substituted compliance, transparency, Policy Makers, European Parliament, Council of the European Union, Hong Kong, Hong Kong Monetary Authority, Securities and Futures Commission, Monetary Authority of Singapore, Singapore, International Organization of Securities Commissions, IOSCO, Department of the Treasury, natural person, foreign entity, Dealer, fiduciary, International Monetary Fund, International Bank for Reconstruction and Development, Inter-American Development Bank, Asian Development Bank, African Development Bank, United Nations,

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,

MFA Comments on Consultation on Increasing Short Position Transparency10.09.09


MFA submitted a letter to the Hong Kong Securities and Futures Commission (SFC) today in response to its Consultation Paper […]

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Topics: Securities and Futures Commission SFC, short positions, Hong Kong, manipulative conduct, short selling, efficiency, liquidity, public disclosure of short positions, price discovery, risk management, financial stocks, net long position, financial services sector, non-public disclosure, confidentiality, market participants, anonymised disclosure, short selling bans, global equity markets, bid-ask spreads, short sellers, short selling disclosure regime, transparency, cash markets, close out indicators, on-market transactions, derivatives, exchange trading, off-exchange transaction, hedging strategies, stocks, delta adjusted, designated securities, listed corporations, non-designated securities, OTC transaction, dual-listed securities, CESR, pan-European short selling disclosure regime, primary market, Hong Kong market, net short positions, transitory short position, reporting threshold, FSA, Financial Services Authority, Securities and Exchange Commission, SEC, turnover ratio, price volatility, capital raising, settlement, SEHK, market volatility, investment managers, private reporting, chilling effect, market efficiency, price formation, short squeeze, herding, volatility, institutional investors, retail investors, transaction costs, alternative investment classes, pensions, endowments, foundations, market liquidity, capital formation, convertible arbitrage, convertible bonds, copycat behavior, proprietary research, market making, Journal of Finance,