MFA Comment Letters

Topic: interest rates

MFA Files Amicus in Lehman Litigation to Support Judicial Asset Sale Process09.28.12


MFA filed an amicus brief in the Barclays Capital and LBI SIPA Trustee litigation before the Second Circuit Court of […]

Click to expand relevant topics

Topics: amicus brief U.S. Court of Appeals for the Second Circuit, Lehman Brothers Holding Inc., Barclays Capital, James W. Giddens, Securities Investor Protection Corporation Trustee, amicus curiae, capital markets, no-cash deal, bankruptcy, Bankruptcy Code, Acton v. Fullmer (In re Fullmer), Adelphia Recovery Trust v. HSBC Bank USA (in re Adelphia Recovery Trust), Bass v. Parsons (In re Parsons), Big Shanty Land Corp. v. Comer Props. Inc., Folger Adam Security Inc. v. Dematteis/MacGregor, In re Cavalieri, In re Cedar Tide Corp, In re F.A. Potts & Co., In re Fehl, In re Gulf Coast Oil Corp., In re Integrated Res. Inc., In re Sapolin Paints Inc., In re Savage Indus. Inc., In re Silver Bros. Co., In re Smith, In re Weisser Eyecare Inc., M.R.R. Traders Inc. v. Cave Atlantique, Matter of Pease, Med. Malpractice Ins. Ass'n v. Hirsch (In re Lavigne), Meinwald v. Meinwald, Morgan Olson LLC v. Federico et al. (In re Grumman Olson Indus. Inc.), United States v. Sforza, Walker v. Lee (in re Rounds), Winston Inn & Rest. Corp. v. DeMichiel (In re Winston Inn & Rest. Corp.), Rob Copeland, Kelly DePonte, Financier Worldwide, Adam Levitin, Richard Mikels, Ella Shenhav, SIFMA, Illinois, Managed Funds Association, MFA, public policy, alternative investment industry, best practices, pensions, endowments, institutional investors, risk management, Australia, Europe, Asia, assets under management, AUM, bankruptcy court, transparency, contract, stakeholders, Clarification Letter, Lehman Margin Cash, purchaser, LBHI, Lori Fife, Harvey Miller, borrowers, lenders, secondary offerings, liquidity, interest rates, debtor, United States Bankruptcy Court for the Southern District of New York, free and clear, banks, New York Adelphia, litigant,

MFA Submits Comment Letter in Response to Basel-IOSCO’s Consultative Document on Margin Requirements for Non-Cleared Derivatives09.28.12


MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision […]

Click to expand relevant topics

Topics: Basel Committee on Banking Supervision International Organization of Securities Commissions, IOSCO, margin, margin requirements, non-centrally cleared derivatives transactions, Working Group on Margining Requirements, derivatives, derivatives markets, margining, clearing, market participants, central clearing, risk management, initial margin, variation margin, best practices, liquidity, mandatory clearing, bilateral exchange, buy-side firms, segregated account, custodian accounts, hedge, hedge funds, netting, eligible collateral, portfolio margining, over-collateralization, mutually offsetting transactions, margin threshold, harmonization, uniformity, non-compliance, regulatory arbitrage, market advantage, phase-in period, implementation timeline, non-cleared derivatives, regulatory authorities, foreign exchange, swaps, forwards, risk profile, market infrastructures, liquidity characteristics, currency, Denominated in G7 Currencies, G7, cleared derivatives, systemic risk, systemic importance, systemically important, systemically important non-financial firm, liquidity costs, unlevel playing field, transparency, SIFI, systemic risk level, credit, unsecured credit extension, minimum transfer amount, MTA, prudentially regulated financial counterparties, two-way margining, standard practice, credit risk, clearing house, bilateral exchange of variation margin, market liquidity, credit default swap, CDS, novation, remaining party, party stepping out, party stepping in, novating parties, market value, Regulators, novation arrangements, liquidity mechanism, asset classes, liquidation, Dodd-Frank Act, European Union, EU, United States, ISDA, International Swaps and Derivatives Association, replacement transaction, market practices, cross-product master netting agreements, risk offsets, financial instruments, U.S. Treasury futures, Eurodollar futures, non-cleared interest rate swaps, repurchase agreements, correlated financial instruments, quantitative impact study, Portfolios, central counterparty, CCP, hedged portfolios, prudential regulators, risk characteristics, risk/reward profile, diversification, concentration limits, haircuts, segregation, third-party segregation, re-hypothecation, cost mitigation, Commodity Futures Trading Commission, CFTC, swap dealers, major swap participants, equities, delta, interest rates, CDS spreads, notional value, commodities,

MFA Submits Amicus Brief on Issue of Creditor Coordination06.29.12


On June 29, MFA filed an amicus brief in the 11th Circuit en banc review of the CompuCredit case.  At […]

Click to expand relevant topics

Topics: U.S. Court of Appeals for the Eleventh Circuit Compucredit Holdings Corporation v. Akanthos Capital Management LLC, Loan Syndications and Trading Association, Securities Industry and Financial Markets Association, SIFMA, Moses Silverman, Aidan Synnott, Daniel Crane, Financial Crisis Inquiry Commission, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, FDIC, Office of the Comptroller of the Currency, Edward Altman, Brendy Kuehne, New York University Salomon Center, Stern School of Business, John Coffee Jr., William Klein, Conrad Duberstein, Tomotaka Fujita, Marcel Kahan, corporate bonds, Michael MacKenzie, Nicole Bullock, Glenn Merrick, Ali Stoeppelwerth, banks, investment banks, broker-dealer, alternative investment industry, securities firms, capital formation, chilling effect, borrowers, distressed debt, contractual relationship, interest rates, creditor, credit squeeze, credit market, bonds, secondary loan markets, institutional lender, leverage, systemic risk, Shared National Credit Review, syndicated loan market, Bondholder, maturity date, debtor, Bankruptcy Filing, Bankruptcy Code, collective action risks, capital, primary market, risk portfolio, U.S. Court of Appeals for the Seventh Circuit, Judge Easterbrook, U.S. Court of Appeals for the Second Circuit, price-fixing, hedge funds, price competition, contract, bilateral monopoly, per se rules, par value, debt instruments, high-velocity market, low-velocity market, creditor coordination, market power, anticompetitive, competition, pre-packaged bankruptcy, Broad. Music Inc. v. Columbia Broadcasting Sys. Inc, Bus. Elecs. Corp. v. Sharp Elecs. Corp., Classic Cheesecake Co. Inc. v. JPMorgan Chase Bank NA, Falstaff Brewing Corp. v. New York Life Ins. Co., Federal Trade Commission v. Brown Shoe Co., Federal Trade Commission v. Indiana Federation of Dentists, Federal Trade Commission v. Superior Court Trial Lawyers Association, Finnegan v. Campeau Corp., United States v. Giordano, Ireland v. Craggs, Leegin Creative Leather Products Inc. v. PSKS Inc., Arizona v. Maricopa County Medical Society, Maris Distrib. Co. v. Anheuser-Busch Inc., National Collegiate Athletic Association v. Board of Regents, Northwest Wholesale Stationers Inc. v. Pacific Stationery & Printing Co., Palmyra Park Hosp. Inc. v. Phoebe Putney Memorial Hospital, Reisner v. General Motors Corp., Reiter v. Sonotone Corp., Sharon Steel Corp. v. Chase Manhattan Bank NA, Smith v. The Ferncliff, State Farm Mutual Auto. Ins. Co. v. Physicians Injury Care Center Inc., United States v. Topco Assocs Inc., Twin City Pipe Line Co. v. Harding Glass Co., Unijax Inc. v. Champion International Inc., United Airlines Inc. v. U.S. Bank NA, Volt Info. Scis. Inc. v. Board of Trs. of Leland Stanford Jr. University,

MFA Submits Comments to ESMA on Short Selling and Sovereign CDS03.09.12


MFA submitted comments in response to ESMAs public consultation on possible delegated acts concerning the Regulation on short selling and […]

Click to expand relevant topics

Topics: European Securities and Markets Authority ESMA, Regulation on short selling and certain aspects of credit default swaps, uncovered short sales and credit default swaps, Level 2 process, natural or legal person, short sale, civil law, securities law, sovereign issuer, EU Member State, net short positions, sovereign debt, long positions, convertible bond positions, France, Spain, Italy, Belgium, issued share capital, convertible debt securities, holding a share, financial instrument, short selling bans, quantitative threshold for high correlation, market participants, buffer periods, interest rates, Instituto de Credito Oficial, ICO, Ministry of Economy and Finance, Secretariat of State for the Economy, Financial Agency of Spain, liquid market price, maturity bucket, delta adjusted method, notional basis, convertible debt, broad-based indices, Eurostoxx, narrow-based indices/baskets, sector-specific, underlying shares, disaggregation, financial institutions, UK Financial Services Authority, FSA, anti-avoidance provision, publicly available information, debt instruments, Alternative Investment Fund Managers Directive, AIFMD, credit quality, yield curve, sensitivity adjusted method, ETF, fund management activities, aggregation of positions, netting, pan-European short selling disclosure regime, CESR, delegate, group, consolidated accounts, credit default swap, default risk, uncovered credit default swap, sovereign CDS, hedged portfolios, asset managers, correlation test, intra-Member State correlation, subordinated debt, trust preferred securities, RBS, BNP Paribas, Societe Generale, interest rate swap, IRS, bank name CDS, emergent systemic risk, Greece, Ireland, Austria, Portugal, IRS curve, Italian CDS, sovereign bonds, credit protection, anticipated correlation, tail risk hedging, tail risk, severe market turmoil, reference asset, contract of insurance, Leonard Ng, Buttersworth Journal of International Banking and Financial Law, insurable interest, indices, supra-national European body, Markit iTraxx SovX Western Europe Index, proprietary models, listed securities, CDS transaction, eurozone, Italian lira, redenomination, uncovered position, static or dynamic hedging strategy, indirect exposures, threshold of liquidity, OTC instruments, legitimate market operations, illiquid shares, corporate bonds, money market instruments, UCITS, short selling, margin level, clearing house, option, future, swap, forward rate agreement, derivative instrument, central clearing, Italian CONSOB, convertible bonds, Member State regulator, sovereign CDS transactions,

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

Click to expand relevant topics

Topics: private funds commodity pool operators, commodity trading advisors, Form PF, systemic risk, Financial Stability Oversight Council, market participants, managed futures, absolute return strategies, SEC, CFTC, Dodd-Frank Act, Council and Office of Financial Research, OFR, global regulators, overcounting, undercounting, threshold for enhanced performance, assets under management, reporting period, confidentiality protections, inadvertent disclosure, non-bank financial companies, lending institutions, interconnectedness, liquidity risk, maturity mismatch, regulatory scrutiny, systemically significant, Federal Reserve System, the Fed, Form CPO, Form PQR, Form CTA-PR, targeted requests, tiered reporting system, threshold, trading and investment strategies, borrowing arrangements, collateral practices, operational capabilities, illiquid assets, investment advisers, bespoke contracts, private equity, privately issued convertible bonds, equity derivatives, distressed debt, unaffiliated third party sources, generally accepted accounting principles, GAAP, Level 2 inputs, Level 3 inputs, Financial Accounting Standards Board, audited financial statements, UK Financial Services Authority, FSA, Form 13F, public companies, Form 10-K, Form 10-Q, portfolio management, CUSIP number, semi-annual reporting, counterparty exposures, market noise, short-term market fluctuations, margin requirements, hedge fund defaults, large private fund manager, qualifying fund, hedge fund assets under management, Form ADV, proposed reporting thresholds, interpretive guidance, private fund managers, recordkeeping requirements, section 404, confidentiality of information, proprietary information, Investment Adviser Registration Depository, Schedule 13G, individual certification, valuation methodology, proprietary methodology, alternative methodology, de minimis, master-feeder, parallel funds, equity prices, interest rates, currency rates, Form PF question 36, form PF questions 28 and 35, funds of funds, direct investments, aggregate gross asset value, collateral, operational efficiency, ten-year option, five-year option, master agreement, regulatory assets under management, net assets under management, leverage, parallel managed accounts, net asset value, gross asset value, creditor, net borrowings, aggregate borrowings, beneficial owners, record owners, fixed advisory fees, investment expenses, performance fees, inception class, statistical arbitrage-equity, other quantitative strategies, strategy exposure, risk capital allocation, NAV, futures commission merchants, FCMs, direct clearing members, DCMs, prime brokers, clause (iii), loan commitments, offsetting exposure, tri-party collateral accounts, market value, asset-backed securities, debt securities, swap contracts, futures contracts, foreign currency contracts, notional value of derivatives, notional amount, long positions, short positions, LMV, SMV, maturity brackets, short-term interest rate, DV01, CR01, duration, non-rated issues, short term high quality corporate debt, foreign exchange derivatives, turnover rate, GMV, Bloomberg, risk methodology, repos, sensitivity analyses, liquidity management, balance sheet value, delta adjusted, variation margin, equity exposure, rehypothecated initial margin, CCPs, central clearing counterparties, Value at Risk, VaR, CDS, CDX, default rates, corporate bonds, short borrowing, synthetic borrowing, uncommitted lines of credit, side pocket arrangement,

Supervisory Commitment Letter on OTC Derivatives Initiatives03.31.11


The MFA, along with several other major financial institutions, submitted this letter to William C. Dudley of the Federal Reserve […]

Click to expand relevant topics

Topics: Federal Reserve Bank of New York G-14, buy-side institutions, signatories, Over-the-Counter, OTC, derivatives, OTC derivatives risk management, market structure, OTC Derivatives Supervisors Group, central clearing, bilateral risk management, transparency, Federal Reserve System, Commodity Futures Trading Commission, CFTC, Connecticut Banking Department, Federal Deposit Insurance Corporation, Federal Reserve Bank of Richmond, Autorite de Control Prudential, ACP, German Federal Financial Supervisory Authority, Japan Financial Services Agency, New York State Banking Department, Office of the Comptroller of the Currency, Securities and Exchange Commission, SEC, Swiss Financial Market Supervisory Authority, United Kingdom Financial Services Authority, Alliance Bernstein, Bank of America-Merrill Lynch, Barclays Capital, Blackrock Inc, Blue Mountain Capital Management LLC, BNP Paribas, Citadel LLC, Citi, Credit Suisse, Deutche Bank AG, D.E. Shaw & Co L.P., DW Investment Management LP, Goldman, Sachs & Co, Goldman Sachs Asset Management L.P., HSBC Group, International Swaps and Derivatives Association Inc, J.P. Morgan, Managed Funds Association, Morgan Stanley, Pacific Investment Management Company LLC, The Royal Bank of Scotland Group, Asset Management Group of the Securities Industry and Financial Markets Association, Societe Generale, UBS AG, Wells Fargo Bank N.A., Wellington Management Company LLP, Committee on Payment and Settlement Systems, European Commission, European Central Bank, European Securities Markets Authority, Financial Stability Board, Bank of England, international regulatory coordination, standardization, data reporting, flexibility, market regulation, global derivatives, reporting, G20, automated processing, uncleared transactions, disputed margin calls, steady state, standardization benchmarking, standardization matrix, standardization narrative, flow/activity data, quantitative stock, credit, equity, interest rates, column-wise functional area, Commodities Steering Committee, Commodities Major Dealers, CMD, Foreign Exchange/Currency Derivatives Major Dealers, Simple instruments, Complex Exotic Instruments, Financial Markets lawyers Group, FMLG, baseline metrics, Equity Derivatives Definitions, 2011 EDDs, Master Confirmation Agreements, MCA, Matrix Working Group, Transaction Supplement, Equity Steering Committee, ESC, operation efficiency targets, trade repositories, infrastructure providers, matching and confirmation, affirmation, lifecycle events, Credit Implementation Group, CIG, equity derivative, operational performance targets, electronically eligible conformations, platform convergence, trade lifecycle event processing, Equity Determinations Committee, EDC, Interest Rate Derivative, functionality, middleware platforms, granularity, Trade Date submission, currently eligible transactions, statutory clearing requirements, submission targets, uncollateralized payable, offsetting CDS hedge, direct buy-side clearing models, indirect buy-side clearing models, product pipeline, sovereigns, FRAs, amortizing swaps, HUF, CZK, SGD, enhanced financial safeguards, cross-currency swaps, caps, floors, European swaptions, inflation swaps, trade date repositories, enhanced clearing penetration, clearing agreement, client onboarding, client collateral, risk issues, compression requirements, margin requirement, liquidity, CPSS-IOSCO, credit default swap, CDS, ISDA Credit Derivatives Determinations Committees, DC, CCP, CDS central counterparties, ISDA 2011 convention on Portfolio Reconciliation and the Investigation of Disputed Margin Calls, ISDA 2011 Formal Market Polling Procedure, Dispute Resolution, portfolio reconciliation, collateral disputes, dispute reporting, prudential regulator, ISDA Minimum Market Standards for Portfolio Reconciliation, electronic messaging, portfolio compression, commodity derivatives, foreign exchange derivatives, interest rate derivatives, residual risk position, regular compression cycles, tear-up algorithms, compression MIS, automatic compression, FX derivatives, aggregate compression yields, trade repository infrastructure, market participants, international data standards, IGC Data Working Group, DWG, legal entity identifiers, LEI, FpML Standards Committee, tradable instruments, cost-recovery, standardized representation, unique product identifiers, Interest Rate Derivatives Trade Reporting Repository, IRRR, Request for Proposal, RFP, Phase II Repository Reporting Expectations, OTC Derivatives Regulatory Forum, ODRF, transaction level data submissions, trade pairing process, COSC, FXMD, International Organization of Securities Commissions, IOSCO, LEAP, EFET, ISDA, IETA, LMBA, copper records, Warehouse Trust, New "Gold" Products, Trade Information Warehouse, recovery lock transactions, client data confidentiality, EMIR legislation, FX Volatility Swap, Cross-Currency Guide, FX Novation Protocol, European Interdealer Index Swap, European Interdealer Fair Value Swap, EMEA EM Interdealer Options, Cash Flow Matching for Equity Derivative Transactions, Allocations, Trade Affirmation, Interoperability, MarkitSERV, MarkitWire, DTCC, Credit Derivative Tranche Transactions, Sukuk Corporate, ISDA Credit Derivatives Physical Settlement Matrix, Credit Derivatives 2010 Documentation Update Working Group, CDD, Small Bang Protocol, Restructuring Credit Event, Anglo Irish Bank Corporation Limited, novation consent, Novation Consent Platform, European MBS, Fixed Recovery Swaps, Swaptions on Indices, iTraxx Europe Untranched Swaption transactions, CDX Untranched Swaption transactions, NDOs, Vanilla Options, Simple Exotic Options, Core FX, NDFs, Continuous Linked Settlement system, CLS, dealer to dealer clearing, LCH.Swapclear, Rates TRR aggregate reporting, zero coupon swaps, single currency basis swaps, extending operating hours, end user clearing, ICE Trust, ICE Clear Europe, dispute resolution procedures, inter alia, Global Compression, CLS Aggregation Service, Core FX settlement processing, ODSG, Equity Derivative Reporting Repository, EDRR, trickle down effect,

Comment Letter to the CFTC in Response to its Request for Comments on Position Limits for Derivatives03.28.11


MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains […]

Click to expand relevant topics

Topics: CFTC Commodity Futures Trading Commission, position limits, derivatives, futures, option contract, swap contract, futures market, price risk, commercial participants, operating company, financial institution, energy market infrastructure, liquid price discovery, risk-shifting market, market manipulation, federal limits, crowding out provision, spot month, disaggregation relief, deliverable supply, inter-commodity spread transactions, bona fide hedger, price discovery, risk management, commodity market, annual recalculation methodology, U.S. futures exchange, delivery point, individual class rules, legacy position limits, agricultural commodities, disorderly markets, spot-month position limits, referenced contracts, aggregate spot-month position limits, swaptions, DCMs, physically delivered contracts, cash-settled contracts, conditional-spot month limit, cash position, forward position, physical commodity deliverable, aggregate all-months-combined, aggregate single-month, futures class all-months-combined, futures class single-month, swaps class all-months-combined, swaps class single-month, open interest, non-spot position limits, calendar-spread exemption, hedging transaction, cash market transaction, cash market risk, swap dealer hedge exemption, pool participant, future commission merchants, FCMs, independently controlled and managed trader, account aggregation requirements, enumerated agricultural commodities, open interest formula, position visibility, reporting requirements, offsetting positions, excessive speculation, interstate commerce, physical commodity, interest rates, stock indices, squeezes, market liquidity, global commodity, regulatory oversight, risk transfer, energy price volatility, CTFC Inter-Agency Task Force on Commodity Markets, GAO, IOSCO, IMG, UK Treasury, CME, The Economist, supply and demand, U.S. dollar, price volatility, NYMEX crude oil price, speculative investment, crude oil futures, International Organization of Securities Commission, IOSCO Technical Committee, IMF World Economic outlook, HM Treasury Global Commodities, OECD publishing, JP Morgan, long positions, hedge funds, short positions, Chicago onions, Berlin wheat, Credit Agricole, Energy Risk, University of Calgary, PKVerleger LLC, Wall St. Journal, Artificial limits, Barclays Capital, OECD Food, Jacks Study, Commission Energy Complex Report, Global Energy Management Institute, Bauer College of Business, University of Houston, House Committee on Agriculture, Pirrong Testimony, price spikes, agricultural model, metal commodity, seasonal variation, market surveillance, OTC, WTI, independently controlled accounts, independent third party, commodity trading advisors, common parent, CPO, CTA, control standard, commodity pool operator, commodity trading advisor, eligible entity, order routing arrangement, disclosure documents, non-financial entity exemption, active trading program, passive trading program, funds of funds, private equity investments, passive investors, pension plan, independent account controller exemption, asset manager, corporate enterprises, speculative trading ventures, CFTC docket no. 11-05, CFTC docket no. 08-02, pool participant exemption, equity interest, market depth, no-action relief, percentage interest, real-time basis, university endowment, liquidity provisions, application based exemption, approval based exemption, annual renewal based exemption, self-executing disaggregation, reporting obligation, surveillance, audit, enforcement, cross-ownership of traders, statement of reporting trader, benchmark contracts, NYMEX Henery Hub Natural Gas contract, commercial hedgers, inter-commodity spread exemption, arbitrage exemption, directional position, outright positions, submarket, large trader data, seasonality, annual limits, CBOT, NYBOT, KCBOT, pre-existing position exemption, significant price discovery contracts, index fund manager, class limits, rounding, hypothetical portfolios, cleared bilateral contracts, non-cleared bilateral contracts, front month position, deferred month positions, last day swaps, penultimate swaps, options, delta, financial cal spread options, physical cal spread options, physical options, HH natural gas,

MFA Joins Amicus Curiae Brief in the case of Hunter v. FERC Regarding Jurisdiction to Regulate Futures Trading07.08.10


MFA, together with FIA, CME and NFA, filed an amicus curiae brief in the Hunter v. FERC case. In our […]

  • Page
  • 1