MFA Comment Letters

Topic: market risk

MFA Submits Comments to the FSB/IOSCO on Assessment Methodologies for Non-Bank Non-Insurer Global SIFIs04.07.14


MFA submitted a comment letter to the Financial Stability Board and the International Organization of Securities Commissions in response to […]

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 Comments to SEC Supporting ICE Clear Credit’s Portfolio Margining Petition06.13.12


MFA submitted a comment letter to the SEC in support of ICE Clear Credit LLC’s portfolio margining petition.  In the […]

Comment Letter to ESMA on its Draft Technical Advice to the European Commission for Implementing AIFMD09.13.11


MFA submitted comments to ESMA on its consultation on possible implementing measures of the Alternative Investment Fund Managers Directive (AIFMD). […]

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Topics: AIFMD the directive, Level 2, third party managers, European Commission, consultation paper, AIF, UCITS Directive, MiFID, professional investors, retail investors, marketing, counterparties, prime brokers, net asset value, Article 61, AUM, AUM Calculations, mark-to-market, EU investors, sub-investment managers, Dodd-Frank, U.S. Securities and Exchange Commission, SEC, Investment Advisers Act of 1940, Advisers Act, registration, private funds, G-20, international coordination, Article 3(2), Article 9(3), professional indemnity insurance requirements, Gross Method, exposure, leverage, foreign exchange hedging position, interest rate hedging position, Box 93, Box 2, Box 1, NAV, Advanced Method, Box 13, diligence requirement, OTC transaction, securities lending agreement, repurchase agreement, Box 19, Box 29, risk management, risk limits, operational risk, portfolio management, market risk, portfolio risk, liquidity risk, gates, side pockets, redemption policy, depositaries, depositary, bespoke system, Box 78, collateral directive, Box 79, liability standards, Financial Services Authority, FSA, re-hypothecation provisions, Box 81, Box 86, due diligence, sub-custodian, Box 88, segregation, Box 89, omnibus accounts, liability regime, Box 95, Box 99, Value at Risk, VaR, Commitment Method, European Central Bank, ECB, Committee on European Securities Regulators, CESR Guidelines, credit default swap, CDS, remuneration, EU Passport, transparency, Box 106, passport regime, safe-keeping function, confidentiality, proprietary information, systemic risk, semi-annual reporting, collateral, counterparty exposures, Form PF, reporting period, generally accepted accounting principles (GAAP), Level 2 inputs, Level 3 inputs, valuation agents, underwriters, unobservable,

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,

MFAs Response to Proposed Regulation of OTC Derivatives, Central Counterparties and Trade Repositories11.11.10


MFAs Response to Proposed Regulation of OTC Derivatives, Central Counterparties and Trade Repositories

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Topics: Proposed Regulation of OTC Derivatives European Union, central clearing, derivatives market, European Commission, Council on OTC Derivatives, Central Counterparties and Trade Repositories, Over-the-counter Derivative Market, OTC, Risk Management Activities, Market Particpants, Class of Derivatives, clearing, Manadatory Clearing Obligation, interest rate swaps, IRS, central counterparties, CCPs, European Securities and Markets Authority, ESMA, European Parliament, Council of Ministers, financial counterparty, Alternative Investment Fund, investment manager, Derivative Contracts, clearing obligation, operational risk, counterparty risk, transparency, competition, Top Down, Bottom Up, Determination Process, Trade Reporting Obligations, risk mitigation techniques, Segregated Exchange of Collateral, Proportionate Holding of Capital, capital requirements, Collateral Posting, Segregate and Exchange Margin, Hold Capital, initial margin, variation margin, Mark-to-Market Changes, Follow-on Effects, Market Exposure, Maximum Time Lag for Confirmation, systemic risk, third country CCPs, Non-European Countries, non-discriminatory access, Interoperability, Equivalency Test, Cross-Border Efficiency and Consistency, risk committees, Effective Supervision, Co-Operation Arrangement, Particpation Requirements, Admissable Clearing Members, Standard Capital Requirements, segregation, portability, Protection of Client Positions and Collateral, U.S. Treasury and U.S. Commodity Futures Trading Commission, U.S. House of Representatives Committee on Financial Services, U.K. House of Lords, European Policymakers, Insolvency Regimes, Unwinding Costs, Swiftly Collapse Offsetting Positions, Optimal Netting, Derivative Contract's Lifecycle, client collateral, Risk Profiles, Financial Strength, default, Trigger, Shortfall, Unmanageable Risk, capital formation, Investment Policy, Highly Liquid Collateral, Minimal Credit Risk, Highly Liquid Financial Instruments, market risk, credit risk, Highly Liquid, Denominated in G7 Currencies, Government Securities, default procedures, confidentiality, trade repositories, competent authorities, reasonable threshold, nexus, Coordination with Third-Country Regulators, Central Banks,

MFA Comments to SEC on Interim Final Temporary Amendments to Regulation SHO12.15.08


MFA sent a letter to the SEC providing comments to the Commission’s interim final temporary rule on amendments to Reg […]

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Topics: Securities and Exchange Commission SEC, emergency orders, short selling, manipulative naked short selling, market dislocations, market participants, liquidity, public interest, efficiency, competition, capital formation, Financial Industry Regulatory Authority, FINRA, broker-dealer, naked short selling, pricing efficiency, Short Selling Activity in Financial Stocks, SEC July 15 Emergency Order, Arturo Bris, European Corporate Governance Institute, Yale International Center for Finance, three-day settlement cycle, capital raising, risk management, derivatives hedging strategies, hedging, distressed companies, capital, market risk, "delta" hedge, volatility, public companies, fails to deliver, securities, close-out, Voting Rights, prime broker, algorithmic trading, automated trading, manual trading, short selling regulation, clearing, settlement, uptick rule, sell-side firms, buy-side firms, hard to borrow shares, easy to borrow shares, locate, threshold securities list, threshold securities, self-regulatory organization, SRO, short positions, short squeeze, operational efficiency, bid-ask spreads, options, market maker, long sales, market efficiency, market liquidity, delivery, securities depositaries, custodian banks, executing brokers, Continuous Net Settlement, National Securities Clearing Corporation, NSCC, clearing agency, settlement date, market distortions, order to purchase, artificial buying pressure, borrowing costs, G19, G19 securities, Wall St. Journal, regulatory efficiencies, mandatory close-out, T+5, T+2, T+4, pre-fail credit, NYSE, New York Stock Exchange, debt securities, arrangement to borrow,

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,