MFA Comment Letters

Topic: overnight borrowing

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, […]

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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 to Responding to ESMA’s Call for Evidence Regarding Level 2 Implementation of the Alternative Investment Fund Managers Directive01.14.11


On January 14, MFA submitted comments to the European Securities and Markets Authority (ESMA) in response to a call for […]

Comment Letter Responding to the Financial Stability Oversight Council’s Advance Notice and Request for Comment on the Criteria for Designating a Nonbank Financial Company as Systemically Important.11.05.10


MFA submitted a comment letter to the Financial Stability Oversight Council in response to the Councils advance notice and request […]

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Topics: Systemically Important Institutions Financial Stability Oversight Council, FSOC, Nonbank Financial Company, Systemically Important Financial Companies, market participants, Systemic Risk Monitoring, Board of Governors, Federal Reserve System, Systemically Relevant Firms, Congress, "too big to fail, U.S. Financial Stability, hedge funds, Financial Market Participants, counterparty risk management, banks, broker-dealer, hedge fund industry, collateral, Borrowing, counterparties, capital markets, financial system, global mutual fund industry, U.S. Banking Industry, systemic risk, assets under management, leverage, Colombia University, Investment Company Institute, Federal Financial Institutions Examination Council, BofA Merrill Lynch, risk monitoring, due diligence, Collateral Posting, credit exposure, Structure of the Industry, Financial Assets, investment portfolio, sophisticated investors, ultra-high net worth individuals, retail investors, diversified portfolio, Liquidity Restrictions, Periods of Redemption, Redemptions, gates, Side Pocket Vehicles, Highly Illiquid Assets, alignment of interests, performance fees, high water marks, risk-adjusted returns, Legally Distinct Funds, Common Adviser, financial institutions, insurance companies, Long Term Capital Managment, LTCM, Position Size, Inadequate Counterparty Risk, leverage ratio, OTC Derivatives Trades, OTC, Counterparty Risk Management Policy Group, Fed Chairman Bernanke, Securities Exchange Commission, SEC, regulatory regime, over-the-counter derivatives, Standardized Transactions, swap dealers, major swap participants, CFTC, Cleared Transaction, Uncleared Transaction, margin requirements, prime brokerage, Short-Term Funding, overnight borrowing, asset mix, off-balance sheet exposures, bank holding companies, Equity Capital Stability, FDIC, FDIC deposit insurance, Debt Guarantees, Government-Issed Charter, Government-Funded Capital, Troubled Asset Relief Program, TARP, Federal Reserve's Discount Window,
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