MFA Comment Letters

Topic: msp

MFA and AIMA Submit Joint Letter to CFTC on Further Proposed Cross-Border Guidance02.06.13


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (CFTC) on its “Further Proposed Guidance […]

Click to expand relevant topics

Topics: Commodity Futures Trading Commission CFTC, Cross-Border, swaps, duplicative regulation, Alternative Investment Management Association, AIMA, Dodd-Frank Act, prime brokers, hedge fund managers, U.S. person, interpretive guidance, market participants, Corporation, partnership, Limited Liability Company, LLC, Trust, joint-stock company, direct or indirect ownership, commodity pool, pooled accounts, collective investment vehicles, commodity pool operator, CPO, pension, estate, income tax, principal place of business test, investment manager, limited liability partnership, LLP, investment fund, ownership test, derivatives, OTC derivatives, over-the-counter derivatives, OTC derivatives market, international harmonization of regulations, regulatory framework, swap dealer, Major Swap Participant, msp, Securities and Exchange Commission, SEC, European Securities and Markets Authority, ESMA, European Parliament, Council of the European Union, central counterparty, CCP, trade repositories, mandatory clearing requirements, clearing, central clearing, systemic risk, Gary Gensler, Mary Schapiro, OTC derivatives reform, CPPSS-IOSCO, IOSCO, International Organization of Securities Commissions, European Union, EU, Hong Kong Monetary Authority, Hong Kong, Monetary Authority of Singapore, Singapore, MAS, foreign regulators, Dealer, buy-side market participants, registration, adviser registration, Office of the Comptroller of the Currency, OCC, majority ownership, Look Through, fund of funds, listed entity, Form CPO-PQR, de minimis, commodities, phase-in period, execution, G20, G20 commitments, transparency,

Comment Letter to the CFTC on Governance Requirements for Derivatives Clearing Organizations, Designated Contract Markets, and Swap Execution Facilities; Additional Requirements Regarding the Mitigation of Conflicts of Interest03.07.11


MFA submitted a comment letter to the CFTC on Governance Requirements for Derivatives Clearing Organizations, Designated Contract Markets, and Swap […]

Comment Letter to the SEC and CFTC on Definitions of “Swap Dealer, Security-Based Swap Dealer (together, SDs), Major Swap Participant, Major Security-Based Swap Participant (together MSPs) and Eligible Contract Participant (ECP)02.22.11


MFA submitted a comment letter to the SEC and CFTC on their joint proposed rule to further define swap dealer, […]

Click to expand relevant topics

Topics: Commodity Futures Trading Commission Securities Exchange Commission, CFTC, SEC, Swaps dealer, SD, Security-Based Swap Dealer, Major Swap Participant, Major Security-Based Swap Participant, msp, security-based swaps, market activity, market growth, systemic risk, United States financial markets, potential future exposure test, systemically important, MSP thresholds, Dealer, end-users, default risk, risk-mitigating tools, hedge fund managers, potential future exposure calculation, over-collateralization, current uncollateralized outward exposure test, independent amount of collateral, initial margin, mark-to-market exposure, ISDA master agreements, daily variation margin calls, valuation of collateral, future exposure discount, centrally cleared positions, central clearing, clearing member defaults, clearinghouse, variation margin, daily volatility, risk mutualization, discount factor, independent variable, tools of credit protection, reproducible test, credit default swaps, CDS, index CDS, unpaid premiums, portfolio risk, fixed downside risk, interest rate swap, LIBOR, swap rate, market-standard discount rate, CDS protection, index reference entity, volatility, jump-to-default risk, single-name CDS, risk factor multiplier, high yield credit swaps, investment-grade credit swaps, credit spreads, credit ratings, investment grade, non-investment grade, margin methodologies, bank capital standards, Chicago mercantile exchange, CME, Financial Industry Regulatory Authority Inc., FINRA, multiplier, spread bank designation, swap underlier, swaptions, options on a swap, physically settled swaptions, cash settled swaptions, option expiration date, Form PF, delta weighting, Financial Stability Oversight Council, large private fund, smaller private fund, Form PQR, MSP definitions, Proposed Form PF section 1b, question 11, question 27, proposed form PF section 2(a), question 38, proposed form PF section 3, question 47, proposed form PF section 4, question 68, proposed Form PQR, schedule B, question 5, substantial counterparty exposure, MSP test, substantial position, undiversified market participant, counterparty exposure, systemically important financial institution, commercial hedging, index derivatives, commercial loans, mitigating commercial risk, threshold levels, dealers, uncollateralized exposure, potential systemic risk impact, inflation, upward adjustment, U.S. banking system, highly leveraged, liabilities to equity, asset mix, liquidity, liquidity rights, capital markets, secured debt, unsecured debt, short-term leverage, overnight borrowing, short-term financing, highly liquid assets, US Treasuries, longer-term leverage, term borrowings, risk factor multipliers, high-grade corporate securities, FSOC, hedge funds, eligible contract participant, ECP, non-ECP, financial counterparty, traditional commodity pool, Retail Forex Pool, SD obligations, retail cash, currency based institutions, limited purpose designations, minimum duration of status, quarters, deregistration period, reevaluation period, abnormal price movement, applicable MSP thresholds, master-feeder fund, feeder fund, trading entity, MSP determination, Senator Hagan, Senator Lincoln, creditworthiness, know your counterparty requirements, daily mark requirements, trade verification, acknowledgment requirements, fund domicile, manager domicile, reference entity domicile, market location, underlying instrument, counterparty domicile, US entities, non-US entities, non-US domiciled fund, non-US securities, non-U.S. market, offshore fund, non-U.S. regulators.,

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 […]

Click to expand relevant topics

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,

MFA Comments on CFTC Regulatory Intitiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

Click to expand relevant topics

Topics: Commodity Futures Trading Commission CFTC, Securities and Exchange Commission, SEC, financial regulatory system, hedge funds, financial crisis, institutional investors, OTC derivatives market, over-the-counter derivatives market, systemic risk, operational risk, transparency, capital markets, U.S. Banking Industry, Columbia University, Investment Company Institute, Federal Financial Institutions Examination Council, leverage, private investment funds, Investor Protection, market discipline, investor confidence, market stability, risk capital, proprietary strategies, international coordination, financial risk, business risk, swap dealer, swap, Counterparty, market maker, futures commission merchant, FCM, futures, Major Swap Participant, msp, non-swap dealer, AIG, initial margin, variation margin, substantial position, offsetting position, clearing, central clearing, liquidity, regulatory capital requirements, creditor, depositor, Tier 1 capital, pension plans, endowments, cleared swaps, uncleared swaps, security-based swaps, collateral, non-bank MSP, Swap Execution Facility, SEF, equity market, futures market, risk management, central counterparties, CCP, risk model, customer protection, risk committee, proprietary asset, customer asset, third party custodian, segregation, omnibus account, individual account, reporting, Designated Contract Market, market integrity, physical market, position limits, contract market, commodity trading advisor, CTA, investment adviser, Peavey Commodity Futures Fund no-action letter, commodity pool operator, Financial Stability Oversight Council, FSOC, Office of Financial Research, owned funds, residual value, managed funds, investment portfolio, roll-over, commercial paper, credit exposure, Federal Deposit Insurance Corporation, FDIC, Troubled Asset Relief Program, TARP, Federal Reserve, "too big to fail, bankruptcy law, Bondholder,