MFA Comment Letters

Topic: liquidation

MFA and AIMA Submit Joint Letter on FSB Consultation on Key Attributes of Resolution Regimes for Non-Bank Financial Institutions10.15.13


MFA and AIMA submitted a joint letter to the Financial Stability Board (IOSCO) in response to its consultative document on […]

MFA Submits Letter and White Paper on Protection of Non-Public, Sensitive, and Proprietary Information by FSOC Members05.22.13


MFA submitted a cover letter and white paper to each member of the Financial Stability Oversight Council (FSOC) on the […]

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Topics: FSOC Financial Stability Oversight Council, market structure, SEC, CFTC, CTA, CPO, Securities and Exchange Commission, Commodity Futures Trading Commission, Dodd-Frank Act, market participants, financial stability, Managed Funds Association, Department of the Treasury, Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, FDIC, Federal Housing Finance Agency, National Credit Union Administration, Office of Financial Research, Federal Insurance Office, data collection, research, trade sectrets, liquidation, investment advisers, Richard H. Baker, U.S. House of Representatives Committee on Financial Services, data repositories, Trading Activities, harmonization, U.S. securities law, commodity pool operator, commodity trading advisor, self-regulatory organization, SRO, intermediary, broker-dealer, futures commission merchants, FCM, swap data repository, SDR, clearinghouses, systemic risk, Form PF, Form CPO-PQR, Form CTA-PR, registered investment adviser, adviser registration, substituted compliance, confidentiality, inspector general reports, Reverse Engineered, Trade Secrets, front running, SEC Office of Inspector General, Andrei Kirilenko, Adam Clark-Joseph, Jaksa Cvitanic, high frequency trading, National Institute of Standards and Technology, NIST, reporting, President Obama, information security program, Rulemaking, Council of Inspectors General on Financial Oversight, CIGFO, Security-Based Swap Data Repositories, SBSDR, Designated Clearing Organizations, DCO, Richard A. Shilts, legal entity identifiers,

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 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,

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 […]

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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,

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 […]

Comment Letter Regarding SEC Study on the Whether the Establishment of a Self-Regulatory Organization Would Improve the Frequency of Examinations of Investment Advisers12.16.10


MFA submitted a letter today providing comments to the SEC on Section 914 of the Dodd-Frank Act, which requires the […]

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Topics: investment adviser examination self-regulatory organization, SRO, securities market, hedge fund managers, Securities and Exchange Commission, SEC, Commodities Futures Trading Commission, CFTC, private fund manager, capital formation, broker dealers, oversight, derivative, derivatives trading activities, investment activity, insider trading, short selling, Disclosure, purchase, sale, nregistered securities, broker-dealer, clearing agencies, over-the-counter derivatives, OTC derivatives, swap dealers, swaps, major swap participants, msp, initial margin, variation margin, transparency, Transaction Reporting, systemic risk, assets under management, leverage, trading positions, counterparties, liquidation, Investor Protection, Compliance Policies, chief compliance officer, Obama Administration's Financial Regulatory Reform Proposals, Committee on Financial Services, U.S. House of Representatives, Department of Labor, Department of the Treasury, National Association of Securities Dealers, NASD, over-the-counter securities markets, Office of Compliance Inspections and Examinations, OCIE, forensic accounting, compliance, registration, check-the-box, fiduciary duty, securities transactions, investment advisory firm, financial planners, traditional asset management firm, wealth managers, small advisers, mutual fund, pension, FINRA, Financial Industry Regulatory Authority, clearing, custody, securities lending, reporting, Financial Stability Oversight Council, FSOC, Investment Adviser Association and National Regulatory Services, Dodd-Frank Act,