MFA Comment Letters

Topic: Lehman Brothers

MFA and AIMA Submit Joint Letter to ESMA in Response to Call for Evidence on Short Selling Regulation03.15.13


MFA and AIMA jointly submitted a comment letter to ESMA responding to its Call for Evidence regarding its evaluation of […]

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Topics: ESMA European Securities and Markets Authority, AIMA, Alternative Investment Management Association, European Parliament, Council of the European Union, short selling, credit default swap, CDS, short selling regulation, Europe, equity, assets under management, AUM, harmonization, competent authorities, reporting requirements, short positions, European Commission, operational challenges, short selling bans, market participants, securities, sovereign issuer, capital, liquidity, price discovery, market distortions, hedging, risk, sovereign debt, Latvia, bond, sovereign bonds, EU Member State, futures, futures market, public disclosure, stock, reverse engineer, efficiency, short squeeze, volatility, reporting obligation, T+1 reporting, hedge funds, price formation, corporate issuer, Lehman Brothers, duration, delta, derivatives, share capital, index derivatives, AIFMD, MiFID, EMIR, net short position, Belgium, Finland, Germany, Netherlands, BaFin, United Kingdom, Commissione Nazionale per le Societa e la Borsa, Committee of European Securities Regulators, CESR, issued share capital, T+2, Bundesanstalt fur Finanzdienstleistungsaufsicht, settlement, locate, prime broker, index, third party managers, technical standards, non-EU investment firms, extraterritoriality, reasonable expectation, uncovered sovereign CDS, eurozone, mark-to-market, single-name CDS, France, Spain, Italy, trading volume, Steven Maijoor, bid-ask spreads, price efficiency, derivative instrument, depositary receipts, London Stock Exchange, PRNewswire, Stock Exchange Daily Official List, compliance, market disruption, interpretive guidance,

MFA Submits Letter to SEC on Proposed Capital, Margin, and Segregation Rules02.22.13


MFA submitted a comment letter to the Securities and Exchange Commission (SEC) on its proposed rules on “Capital, Margin, and […]

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Topics: Securities and Exchange Commission SEC, margin, capital, segregation, Security-Based Swap Dealer, Major Security-Based Swap Participant, capital requirements, broker-dealer, risk, security-based swaps, customer collateral, Dodd-Frank Act, CFTC, Commodity Futures Trading Commission, Private Funds Managers, Investor Protection, regulation, international regulatory standards, efficiency, capital formation, liquidity, collateral, margin requirements, market participants, variation margin, netting, margining, Financial Industry Regulatory Authority, FINRA, international harmonization of regulations, regulatory arbitrage, federal register, bilateral exchange of variation margin, best practices, counterparty risk, systemic risk, risk management, portfolio margining, securities, cross-product master netting agreements, initial margin, financial system, asset class, counterparties, prudential regulators, leverage, derivatives, tri-party custodial arrangements, customer protection, omnibus segregation, default, fellow customer risk, legal segregation with operation commingling, LSOC, swap dealers, Major Swap Participant, Individual Segregation, buy-side firms, non-commercial end-users, hedge funds, credit risk, capital inefficiency, transparency, Basel Committee on Banking Supervision, International Organization of Securities Commissions, IOSCO, Working Group on Margining Requirements, central clearing, compliance, registered clearing agencies, mandatory clearing, compliance date, two-way margining, reform, collateral management, asymmetrical initial margin exchange, pension, endowments, university endowment, financial crisis, "too big to fail, too interconnected to fail, American International Group, AIG, House Committee on Financial Services, Ben Bernanke, Federal Reserve Board, 111th Congress, financial contagion, financial institutions, asymmetry, portfolio reconciliation, portfolio compression, Swap Trading Relationship Documentation, swap dealer, collateral management stystems, trading costs, complexity, settlement risk, credit default swap, CDS, OTC derivatives, forwards, repurchase agreements, Value at Risk, VaR, financial instrument, cross-margining, Options Clearing Corporation, Chicago Mercantile Exchange Holdings Inc., New York Portfolio Clearing LLC, LCH.Clearnet Ltd., customer replicability, proprietary information, reconciliation, market risk, haircuts, Cash Flow, pro-cyclical effects, creditworthiness, multiplier, customized risk management tools, sell-side firms, liquidation time horizon, product type, market practice, ISDA, U.S. dollar, settlement, money market instruments, eligible collateral, capital charge, Lehman Brothers, bankruptcy, bankruptcy estate, third-party custody arrangement, enhanced protections, Notice of Exclusive Control, Investment Company Institute, ICI, White Paper, Securities Industry and Financial Markets Association, SIFMA, liquidation, Federal Reserve Bank of New York, tentative net capital, dealers, Eric Chern, Chicago Trading Company, \, operational risk, Security-Based Swap Transactions, Darrell Duffie, Federal Reserve Bank of New York Staff Report No. 424, ICE Clear Europe Limited, segregation model, DCO, derivatives clearing organization, portability, insolvency, out-of-the-money, operational and legal commingling, default segregation model, MF Global Inc., Peregrine Financial Group, Fraud, investment risk, Russell Wasendorf, accounting, operational costs, Broker, Dealer, ISDA Margin Survey 2012, European Commission, European Parliament, Council of the European Union, central counterparty, CCP, trade repositories, commodity broker, Bart Chilton, Division of Clearing and Intermediary Oversight, Robert Wasserman, independent third party custodian, state bank regulator, state and federal laws,

Comment Letter on Proposed Rulemaking for Systemically Significant Institutions02.25.11


MFA submitted a letter to the Financial Stability Oversight Council in response to the Councils proposed rule regarding the criteria […]

MFA Comments to the “Over-the-Counter Derivatives Markets Act of 2009”11.09.09


MFA submitted a letter to the Department of the Treasury regarding the Obama administration’s legislative proposal titled the “Over-the-Counter Derivatives […]

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Topics: Department of the Treasury Obama Administration, regulatory framework, over-the-counter derivatives, OTC derivatives, institutional investors, commodity, securities market, OTC derivatives market, derivatives transactions, central clearinghouse, segregation, initial margin, variation margin, trade and position reporting, swap dealers, securities dealers, Major Swap Participant, AIG, end-users, substantial net position, substantial unsecured net position, AAA credit rating, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, CFTC, security-based swaps, dealers, credit risk, insurance companies, energy companies, airline, utilities, private funds, local governmental entities, non-dealer entities, capital restrictions, swap market participant, Long Term Capital Management, Enron Corporation, thrift and insurance holding company, American International Group, unsecured current credit exposure, central clearing, derivatives clearing organizations, proprietary assets, legacy standardized swaps, non-clearable trade, Gary Gensler, Lehman Brothers, LBIE, collateral segregation, bankruptcy-remote, Bankruptcy Code, risk management, Pension Funds, endowments, hedge funds, custodian, ISDA product definitions, registered derivatives clearing organization, non-cleared swap transactions, exchange trading, hybrid market, exchange-traded products, market manipulation, position limits, physically-delivered commodities, cash-settled contracts, pre-merger notification regime, capital formation,

MFA’s Comments to IOSCO on the Consultation Report on Unregulated Financial Markets and Products06.15.09


MFA submitted a letter to the International Organization of Securities Commissions (IOSCO) in response to its Consultation Report on Unregulated […]

MFA Comments in Response to the IOSCO Consultation Report on Hedge Funds Oversight04.30.09


MFA submitted a written response to the IOSCO Consultation Report on Hedge Funds Oversight. MFA’s comments focused on four key […]

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Topics: Technical Committee of the Internationl Organization of Securities Comissions IOSCO, Hedge Funds Oversight: Consulation Report, global crisis, investor confidence, capital markets, Market Confidence, stability, hedge funds, systemic risk, market integrity, Investor Protection, regulation, private pools, capital, Task Force on Unregulated Financial Entities, standardized disclosures, minimum capital requirements, liquidity, price efficiency, global integration, counter-cyclical force, buyers, distressed assets, sellers, selling short, equities, pension plans, endowments, European Commission, EC, alternative investment fund managers, prime brokers, residential mortgage lending, Lehman Brothers, mutual fund, banking, Financial Research Corp. counterparties, Long Term Capital Management, Lord Adair Turner, U.K. Financial Services Authority, FSA, diligence process, Anti-Fraud Provisions, securities laws, transparency, customer collateral, performance compensation, advisory relationships, high-water mark, management fee, insider trading, MFA's Sound Practices for Hedge Fund Managers, over-the-counter derivatives, credit default swaps, CDS, absolute return, Operations Management Group, OMG, Commission Bancaire of France, bilateral solutions, business-process objectives, Fannie Mae, Freddie Mac, equity derivative confirmations, centralized clearing, clearinghouse platforms, President's Working Group's Asset Managers' Committee, Alternative Investment Management Association, Hedge Fund Standards Board, Financial Stability Forum, best practices, public disclosure, proprietary information, moral hazards, orderly dissolution, Rulemaking, G-20, OTC derivatives, Federal Reserve Bank of New York,

MFA Letter to GAO Following Telephone Interview on January 15, 200902.06.09


MFA submitted a letter to the Government Accountability Office (GAO) following its telephone interview on January 15, which was held […]

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