MFA Comment Letters

Topic: omnibus account

MFA Submits Letter to SEC on Sequencing Roadmap for Final Title VII Rules08.13.12


MFA submitted a comment letter to the SEC in response to its Sequencing Roadmap Policy Statement on the compliance dates […]

MFA Submits Letter to ESMA on Draft Technical Standards on OTC Derivatives08.05.12


MFA submitted a comment letter to the European Securities and Markets Authority (“ESMA”) in response to its Consultation Paper on “Draft Technical […]

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Topics: European Securities and Markets Authority ESMA, over-the-counter derivatives, OTC derivatives, CCP, trade repositories, European Parliament, Council of the European Union, OTC derivatives transactions, central counterparty, EMIR, central clearing, systemic risk, transparency, collateral, segregation, regulatory technical standards, straight-through processing, OTC derivatives market, market participants, Dealer, portability, client protections, contractual relationship, clearing member, CPSS-IOSCO, CPSS-IOSCO standards, CCP governing bodies, margin valuation, margin, risk management, risk management framework, conflicts of interest, fiduciary duty, International Organization of Securities Commissions, IOSCO, proprietary trading tools, risk committee, derivatives contracts, derivatives, risk profile, interlocking governance arrangements, trading venues, Commodity Futures Trading Commission, CFTC, Securities and Exchange Commission, SEC, internal controls, over-collateralization, in-the-money swap, "delta" hedge, swaps, credit default swap, CDS, negative correlation, capital, trading costs, credit risk, indirect clearing, non-linear products, Europe, European Union, EU, administrator, omnibus account, default, principal basis, agency basis, gross basis, net basis, LCH Clearnet, indirect client, direct client, close-out, extraterritorial application of EMIR, extraterritoriality, risk mitigation, Dodd-Frank Wall Street Reform and Consumer Protection Act, Asia, regulatory arbitrage, Regulators, counterparty risk, duplicative regulation, mutual recognition, third country regime, interpretive guidance, Cross-Border, index, foreign exchange, Euro, currency, interest rate derivatives, EU Member State, non-cleared OTC derivatives, compliance, default fund, portfolio reconciliation, portfolio compression, self-regulatory organization, SRO, swap dealers, major swap participants, Derivative Contracts, bilateral non-cleared OTC derivatives transactions, execution, hedging, upfront payment, floating rate payment, coupon, maturity, bespoke non-cleared trades, security-based swaps, debt-security based swaps, total return swaps, settlement prices, Proprietary Trading Strategy, public disclosure, confidence interval, margin requirements, financial instrument, posted collateral, interest rate swaps, Stan Ivanov, Lee Underwood, variation margin, initial margin, Basel Committee on Banking Supervision, Basel III, liquidation horizons, bilateral counterparty credit risk, netting, transaction fees, liquidity fragmentation, affiliated market participants, money market instruments, credit institutions, stress testing, back testing,

Comment Letter to CFTC on Proposed Rules Governing Protection of Cleared Swap Customer Contracts and Collateral08.08.11


MFA submitted a comment letter to the CFTC in response to its notice of proposed rulemaking on Protection of Cleared […]

MFA Comments on SEC Regulatory Initiatives 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 […]

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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, 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, 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, private investment funds, mutual fund, client, pooled vehicle, pooled investment vehicle, Investor Protection, self-regulatory organization, SRO, investment adviser examination, Comptroller General of the United States, capital formation, Office of Compliance Inspections and Examinations, OCIE, private funds, global banks, retail clients, proprietary information, Confidential Information, Venture Capital Fund, family office, accredited investor, qualified client, knowledgeable employees, transitional relief, performance reports, market makers, Broker, fiduciary, Major Security-Based Swap Participant, MSSP, registration, margin requirement, risk profile, financial entities, Price Manipulation, executive compensation, many-to-many platform, covered financial institution, Incentive-Based Compensation Arrangements, Regulation D, disqalifying felons, Bad Actors, CUSIP number, short selling, Disclosure, price discovery, volatility, retail funds, global market, equity market, herding, Form SH, beneficial ownership, short swing profit reporting, fiduciary standard, Investor Advisory Committee, European Commission, EC, European Union, EU, European Parliament, EP, European Council of Finance Ministers, alternative investment funds, AIFs, SEC-registered advisers, Secretary Geithner, European Commissioner Michel Barnier, U.K. Chancellor of the Exchequer Alistair Darling, non-bank financial companies,

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 […]

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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,
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