MFA Comment Letters

Topic: investor

MFA Submits Letter in Response to SEC Investor Advisory Committee Recommendations on Implementation of the JOBS Act03.22.13


MFA submitted a comment letter to the Securities and Exchange Commission (SEC) in response to its proposed implementation of Section […]

MFA Submits White Paper to European Commission on Shadow Banking06.01.12


On June 1, MFA submitted a white paper on hedge funds and shadow banking in response to the European Commission’s […]

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Topics: European Commission European Union, EU, Green Paper "Shadow Banking", shadow banking, shadow banking system, systemic risk, Background Note, Background Note "Shadow Banking: Scoping the Issues", Financial Stability Board, FSB, hedge fund industry, credit hedge funds, leverage, investor, counterparties, regulatory framework, regulatory arbitrage, financial industries, mutual funds, banks, financial market, investment strategies, asset classes, liquidity transformation, maturity transformation, risk analysis, liquidity protections, liquidity, equity investors, financial institutions, demand deposit accounts, collateral, margin, deposit-like characteristics, redemption terms, secured borrowings, direct lending, direct loan market, AIFMD, Alternative Investment Fund Managers Directive, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, originator, derivative transactions, total return swaps, secured financing, credit intermediation, non-bank financial insitutions, bank-like activities, maturity tra, G20, nonbank credit intermediation, hedge fund counterparties, broker-dealer, risk management, hidden leverage, bank-like regulation, assets under management, AUM, Securities and Exchange Commission, SEC, state securities regulators, regulatory assets under management, RAUM, U.S. Securities Laws, chief compliance officer, hedge fund managers, Form ADV, investment advisers, Form PF, Commodity Futures Trading Commission, CFTC, Financial Stability Oversight Council, FSOC, commodity futures contracts, swaps, commodity pool, commodity trading advisor, CTA, over-the-counter derivatives, OTC derivatives, central clearing, derivatives, segregation, transparency, major swap participants, swap dealers, derivatives market, Office of Financial Research, OFR, systemically important financial institution, SIFI, Board of Governors of the Federal Reserve System, the Fed, prudential regulation, Doug Elliott, Brookings Institution, absolute risk, Volcker Rule, Long Term Capital Management, "too big to fail, government insurance, market based regulations, House Financial Services Subcommittee on Financial Institutions and Consumer Credit, private equity, venture capital funds, property-casualty insurance, mutual funds management, money market funds, public company equity securities, institutional investment manager, insider trading, Department of the Treasury, Bureau of Economic Analysis, EU Member State, MiFID, Markets in Financial Instruments Directive, European Market Infrastructure Regulation, EMIR, Investment Company Institute, ICI, United Kingdom, counter-cyclical, creditor, taxpayer, sophisticated investors, instant liquidity funds, discount windows, gates, lock-up periods, side pockets, Financial Services Authority, FSA, uncollateralized loans, initial margin, variation margin, asset-backed commercial paper conduits, ABCP conduits, structured investment vehicles, SIV, Columbia University, leverage ratio, Lord Adair Turner, Hedge Fund Research, asset-backed securities, corporate bonds, government bonds, small and medium-sized enterprises, SME, leveraged loan markets, quantitative strategies, credit arbitrage strategies, fundamental credit analysis, distressed restructuring strategies, fixed income instruments, bankruptcy, private issue/Regulation D strategies, Regulation D, private investment in public equity, PIPE, relative value, pricing discrepancy, fixed income - asset backed, loans, credit cards, receivables, real estate, tangible financial commitments, fixed income - convertible arbitrage, convertible arbitrage, fixed income - corporate, corporate fixed income instrument, relative value - multi-strategies, Master Limited Partnership,

Comment Letter to ESMA on Short Selling and Credit Default Swap Regulation01.10.12


MFA submitted a comment letter on January 10 to the European Securities and Markets Authority (ESMA) regarding the implementation of […]

Comment Letter in Response to the FDICs Interim Final Rule Implementing Certain Provisions of the Orderly Liquidation Authority (OLA),03.28.11


MFA filed a comment letter in response to the FDICs interim final rule implementing certain provisions of the orderly liquidation […]

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Topics: Federal Deposit Insurance Corporation FDIC, Liquidation Authority provisions, orderly liquid authority, OLA, creditor losses, shareholder losses, liquidation process, systemically significant firm, non-statutory considerations, Bankruptcy Code, Federal Rules of Bankruptcy Procedure, financial market meltdown, covered financial institution, insolvency laws, insolvency proceeding, investor, systemic risk, transparency, estate, creditor participation, creditor involvement, market expertise, Disclosure, claim disallowance, judicial review, distress, volatility, moral hazard, market discipline, receivership, short-term creditors, debt instrument, allocation of capital, short-term financing, longer-term financing, bond holders, short-term lenders, providers of lines of credit, preferred creditors, equality of distribution, critical vendors, doctrine of necessity, Union Bank v. Wolas, chapter 7 liquidation, favored creditors, unsecured creditors, Board of Directors of FDIC, ratable payments, liquidation value, valuation of collateral, underlying collateral, unsecured claim, fair market value, US government securities, valuation rules, true market valuation, unsecured deficiency claim, quotes, market data, third-party market participants, valuation date, publicly traded securities, secured creditor, receivership estate, market fluctuations, swaps, repurchase agreements, securities contracts, bridge financial company, default, contingent claims, unduly delay, liquidation framework,

Letter to Mary Schapiro; Attachments: (Industry Letter on Buy Side Access to Clearing) and (Recommended Timeline for Adoption and Implementation of Final Rules Pursuant to Title VII of The Dodd-Frank Act)03.24.11


MFA submitted a letter to Chairmen Schapiro and Gensler, and each of the SEC and CFTC Commissioners, providing our recommendations […]

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Topics: Securities and Exchange Commission OTC derivatives market, reform, systemic risk, efficiency, global financial system, central clearing, liquid contracts, clearable contracts, trade repositories, cleared swaps, bilateral swaps, price transparency, liquid swap transactions, broad industry clearing, trade repository data, electronic data, trade transparency, buy-side participants, buy-side access, New York Fed, ISDA Governance Committee, IIGC, standardizing contracts, trade compression, OTC derivatives reform, milestones, phase-in period, sell-side firms, clearinghouses, Regulators, current clearable swaps, future clearable swaps, broad-based index credit default swaps, CDS, interest rate markets, single-name CDS, asset managers, end-users, CCPs, CMs, customer clearing services, open interest caps, waterfalls, block trading, risk compression, customer funds, pre-default portability, give-up agreements, US bankruptcy, non-US bankruptcy, cleared OTC derivatives, 14d order, 17f6 order, SEC exemptions, FINRA exemptions, margin methodology, CME rules, CME, ClearPort, migration, TBF, Bloomberg, MarkitWire, ICELink, end to end production testing, front-office processing, middle-office processing, back-office processing, back loading facility, end-to-end systems flow, fallback processing, post-default portability, risk waterfall process, net client omnibus margin account, price challenge protocol, financial disclosure requirements, clearing, commission fee, trading annex, give up process, transparency, default waterfall, futures, CDS books, margin segregation, Basel I capital requirements, FCMs, commodity contracts, Bankruptcy Code, roll-out schedule, margin regime, vendor, streamlined netting process, trade rejection rights, segregation framework, alternative margin segregation schemes, title transfer regime, English law CSAs, US banking regulators, US bank CM, non-US bankruptcy laws, non-US CM's default, position limits, real-time reporting, big bang approach, phase-in approach, derivatives clearing organizations, interest rate swaps, exchange trading, MSPs, hedge funds, dealer-to-dealer clearing, SEF trading, onboarding, mixed swap, swap dealer, eligible contract participant, DCO governance, DCO registration, collateral, Business Conduct Standards, capital requirements, margin requirements, MSP recordkeeping requirements, SD recordkeeping requirements, public reporting, liquidity, individual risk concentrations, block trade. swap initial margin, post-trade reporting, pre-trade reporting, interdealer reporting, Dodd-Frank clearing requirements, clearing agreement, execution agreement, clearing members, FIA, CFTC rules, SEC rules, mandatory clearing date, CCP implementation period, CCP risk management, end-user exemptions, Phase 1 mandatory cleared products, counterparty risk, OTC derivatives, standardized documentation, onboarding work streams, voluntary period, direct clearing participants, indirect clearing participants, voluntary targets, scale readiness, volume targets, simpler instruments, complex instruments, credit, voluntary back loading, compression, systemic counterparty risk, industry-level metrics, DTCC data, cleared settlement, uncleared settlement, tear-ups, long-only accounts, asset manager accounts, investor,