MFA Comment Letters

Topic: legal risks

Comment Letter to the CFTC on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants02.28.11


MFA submitted a comment letter to the CFTC on its proposal on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for […]

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Topics: Commodity Futures Trading Commission CFTC, confirmation, portfolio reconciliation, portfolio compression requirements, swap dealers, major swap participants, SDs, MSPs, operational abilities, market participants, post-trade exercises, mandated timeframes, Counterparty, trade execution, SEC, Securities and Exchange Commission, valuation data, bilateral portfolio compression exercise, multilateral portfolio compression exercises, swap markets, pre-trade draft acknowledgement requirement, customized swaps, heavily negotiated swaps, time-sensitive swaps, hedging risk, limiting parties, volatility, bid spreads, offer spreads, over-the-counter derivatives, legal risks, rights, trade acknowledgment, consistent timing, confirmation periods, financial entities, pension plans, private funds, insurance companies, banks, swap portfolio trade confirmation, electronic processing, calendar day, financial entity, trade capture system, electronic matching platforms, electronic matching process, complex swap, life cycle events, timing requirements, novation, modification, partial termination, dividend payment, merger, market disruption, compliance period, clearance, exchange execution, clearing satisfying requirements, Designated Contract Market, DCM, Swap Execution Facility, SEF, derivatives clearing organization, DCO, confirmation requirement, collateral management, counterparty risk, market risk, position level discrepancies, margin disputes, position level portfolio reconciliation, best practices, bilateral portfolio reconciliation exercise, multilateral portfolio reconciliation exercise, Valuation Disputes, valuation discrepancy, nominal value, dollar threshold, broader markets, collateral steering committee of the International Swaps and Derivatives Association Inc., ISDA, market-driven solution, portfolio compression rule, operational risk, risk mitigation benefits, multilateral compression, swaps portfolio, liquidity,

MFA Comments to the U.K. Hedge Fund Working Group’s Consultation Paper12.14.07


Today, MFA submitted the following response letter to the U.K. Hedge Fund Working Group on its Consultation Paper. The overall […]

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Topics: Hedge Fund Working Group consultation paper, HFWG, Sound Practices for Hedge Fund Managers, United Kingdom, global relevance, global alternative investment industry, hedge funds, funds of funds, managed futures funds, jurisdictional requirements, fund governing bodies, Third Party Administrators, board of directors, U.S. based funds, net asset value, compliance, Comply or Explain, managers, investors, counterparties, bright line test, Fund Governing Body, President's Working Group on Private Pools of Capital (PWG), Securities and Exchange Commission (SEC), offshore, non-U.S. exchanges, Irish Stock Exchange, Luxembourg Stock Exchange, regulatory implicationsm Websites, segregation, potential conflicts, third parties, Investment Policy, Risk Disclosure, potential liability, Performance Measurement Disclosure, non-marketable, illiquid securities, portfolio, marketable securities, valuation determinations, Chartered Financial Analyst Institute, Global Investment Performance Standards, independent valuation services providers, portfolio management, independent third parties, independent in-house functions, Difficult-to-Value Assets, exchange traded posistions, uncertainity, Fair Value, fire sale, Disclosure, market price, audited annual accounts, side pocket, market risk, stress testing, Governance of Operational Risk, conflicts of interest, compliance procedures, client confidentiality, Outsourcing Risk, service legal agreement, Key Performance indicators (KPis) Fund Governance Disclosure, spectrum, Market Abuse, Insider Dealing, inside information, disclosure thresholds, U.S. securities law, UK, AML, side letters, commercial terms, reconciliation errors, valuation, legal risks, regulatory risks, trade association, board of trustees, investor groups, Regulators, Lenders/Prime Brokers/Dealers, OTC market particpants, cross-market particpant working group, OTC derivatives transactions, Federal Reserve Bank of New York for OTC equity derivatives, OTC electronic transaction posistions, price sources, cherry picking, performance fee, scenario analyses, counterparty risk, netting agreements, collateral agreements, collateral calls/two way collateral posting, soft limits, Model Risk, Key man risk, one-stop shop, prime brokers, Derivative posistions, Borrowed Stock, exposure, stock lender, proxy voting policy, Alternative Investment Management Association, AIMA,
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