MFA Comment Letters

Topic: interest rate swaps

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 Submits Letter to ESMA on Draft Technical Standards on OTC Derivatives08.05.12

MFA submitted a comment letter to the European Securities and Markets Authority (“ESMA”) in response to its Consultation Paper on “Draft Technical […]

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Topics: European Securities and Markets Authority ESMA, over-the-counter derivatives, OTC derivatives, CCP, trade repositories, European Parliament, Council of the European Union, OTC derivatives transactions, central counterparty, EMIR, central clearing, systemic risk, transparency, collateral, segregation, regulatory technical standards, straight-through processing, OTC derivatives market, market participants, Dealer, portability, client protections, contractual relationship, clearing member, CPSS-IOSCO, CPSS-IOSCO standards, CCP governing bodies, margin valuation, margin, risk management, risk management framework, conflicts of interest, fiduciary duty, International Organization of Securities Commissions, IOSCO, proprietary trading tools, risk committee, derivatives contracts, derivatives, risk profile, interlocking governance arrangements, trading venues, Commodity Futures Trading Commission, CFTC, Securities and Exchange Commission, SEC, internal controls, over-collateralization, in-the-money swap, "delta" hedge, swaps, credit default swap, CDS, negative correlation, capital, trading costs, credit risk, indirect clearing, non-linear products, Europe, European Union, EU, administrator, omnibus account, default, principal basis, agency basis, gross basis, net basis, LCH Clearnet, indirect client, direct client, close-out, extraterritorial application of EMIR, extraterritoriality, risk mitigation, Dodd-Frank Wall Street Reform and Consumer Protection Act, Asia, regulatory arbitrage, Regulators, counterparty risk, duplicative regulation, mutual recognition, third country regime, interpretive guidance, Cross-Border, index, foreign exchange, Euro, currency, interest rate derivatives, EU Member State, non-cleared OTC derivatives, compliance, default fund, portfolio reconciliation, portfolio compression, self-regulatory organization, SRO, swap dealers, major swap participants, Derivative Contracts, bilateral non-cleared OTC derivatives transactions, execution, hedging, upfront payment, floating rate payment, coupon, maturity, bespoke non-cleared trades, security-based swaps, debt-security based swaps, total return swaps, settlement prices, Proprietary Trading Strategy, public disclosure, confidence interval, margin requirements, financial instrument, posted collateral, interest rate swaps, Stan Ivanov, Lee Underwood, variation margin, initial margin, Basel Committee on Banking Supervision, Basel III, liquidation horizons, bilateral counterparty credit risk, netting, transaction fees, liquidity fragmentation, affiliated market participants, money market instruments, credit institutions, stress testing, back testing,

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,

Comment Letter on Proposed Rules for Margin Requirements for Uncleared Swaps and Capital Requirements for Swap Dealers and Major Swap Participants07.11.11

MFA submitted a comment letter to the CFTC in response to both their notice of proposed rulemaking on Capital Requirements […]

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Topics: Commodity Futures Trading Commission CFTC, "Proposed Capital Rules, " "Proposed Margin Rules, margin, liquidity, swap markets, prudential regulator, CSE, buy-side firms, central clearing, uncleared swaps, customized transactions, unsecured counterparty credit risk, transparency, margin practices, two-way exchange of variation margin, netting, safeguards. designated clearing organization, DCO, Timothy Geithner, Gary Gensler, counterparties, trading costs, adverse pricing, funding costs, variation margin, collateral management practices, financial entities, non-cash collateral, Office of the Currency, Office of the Treasury, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Farm Credit Administration, Federal Housing Finance Agency, systemic risk, shielding assets, pension plans, university endowments, bilateral variation margin exchange, unsecured obligations, one-sided variation margin arrangements, SEC, "too big to fail, " uncollateralized swap positions, margin exchange, swap portfolio, counterparty credit quality, Hon. Ben S. Bernanke, risk management, asset classes, interest rate swaps, commodity swaps, equity swaps, referenced bond, Eurodollar futures, physically-settling forwards, repurchase agreements, security lending agreements, liened account assets, initial margin model, portfolio offsets, Alternative Method, net counterparty exposure, out-of-the-money swap, in-the-money swap, initial and variation margin transfers, futures commission merchant, asset class, multi-lateral agreements, cross-product netting agreements, non-cleared commodity options, liquidation value, paired products, trading contracts, capital planning, multiplier of 2.0, multiplier of 4.4, reference cleared swap, grid-based method, proprietary models, ten-day liquidation time horizon, five-day time horizon, segregation of customer assets, custodian, Capital Rules, capital requirements, Mr. Eric Chern, Chicago Trading Company, Joint Commission-SEC Staff Roundtable on Proposed Dealer and major Participant Definitions Under the Dodd-Frank Act, tailored products, Reporting of Capital Requirements, collateral delivery, counterparty exposure, Capital Relief for Cleared Swaps,

Comment Letters to Prudential Regulators on their Proposed Rules for Margin and Capital Requirements for Covered Swap Entities07.11.11

MFA submitted a comment letter to the Prudential Regulators in response to their notice of proposed rulemaking on Margin and […]

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Topics: Notice of Proposed Rulemaking on Margin and Capital Requirements for Covered Swap Entities Treasury, swap markets, central clearing, risk-based margin requirements, minimize risk, liquidity, swap dealers, SDs, major swap participants, covered swap participants, CSEs, uncleared swaps, delivery of margin, counterparties, operational costs, adverse pricing, robust netting arrangements, funding costs, customized transactions, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, unsecured counterparty credit risk, consistency, transparency, variation margin, Timothy Geithner, mandatory clearing requirements, central clearinghouse, clearing eligible, non-cash collateral, Gary Gensler, asset class, financial entity counterparties, bilateral exchange of variation margin, pension plans, university endowments, counterparty risk, systemic risk, "too big to fail, uncollaterized swap positions, indirect transmission, House Committee on Financial Services, Ben S. Bernanke, swap portfolio, risk management, cleared swap transactions, risk reduction tool, interest rate swaps, commodity swaps, FCM, credit default swap, referenced bond, interest rate swap, Eurodollar futures, security-based swaps, physically-settling forwards, repurchase agreements, security lending agreements, over-collateralization, futures commission merchant, liquidation value, cross-product netting agreements, multi-lateral netting agreements, non-cleared commodity options, paired products, trading contracts, proprietary models, equity swaps, call option, total return swap, illiquid security, ten-day liquidation time horizon, five-day time horizon, valuation formulas, swap documents, Capital Relief for Cleared Swaps, DCO, capital charge, derivatives clearing organizations, Office of the Comptroller of the Currency, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, Farm Credit Administration, Federal Deposit Insurance Corporation, FDIC, CFTC,