MFA Comment Letters

Topic: regulation

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 Petitions the CFTC to Exclude Certain Employee Pools from the Definition of “Pool”08.30.12


MFA petitioned the CFTC to provide an exclusion from the definition of commodity “pool” for certain internally owned entities, including […]

Comment Letter Responding to FSB’s Background Note, ‘Shadow Banking: Scoping the Issues’05.16.11


MFA submitted a comment letter in response to the FSBs Background Note on Shadow Banking. In our letter, we discussed […]

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Topics: Financial Stability Board Shadow Banking: Scoping the Issues, shadow banking system, banks, broker dealers, Background Note, hedge fund industry, concentration of assets, low leverage, borrowing arrangements, derivatives contracts, stable capital, regulation, credit intermediation chain, Distribution/Wholesale Funding, non-bank institutional investors, long-only mutual funds, insurance companies, Pension Funds, private equity funds, large corporate investors, systemic risk concerns, maturity transformation, liquidity transformation, individual adviser, hedge fund adviser, asset concentration, asset management structures, interconnectedness of hedge funds, systemic impact of hedge funds, The UK Financial Services Authority, FSA, legal separation of different funds, bank holding companies, nonbank financial institutions, secured borrowings, manage liquidity risk, investors, bank/broker counterparts, secured basis, short term liability, repo liabilities, ABCP conduits, mutual funds, collateral, margining process, haircuts, initial margin, mark-to market margining, repo sellers, repo collateral, highly leveraged financial institutions, hedge fund borrowings, Long Term Capital Management, LTCM, U.S. President's Working Group on Financial Markets, counterparty risk management, Counterparty Risk Management Policy Group, hedge fund leverage, regulatory arbitrage, regulatory arbitrage concerns, off-balance sheet vehicles, direct regulation of entities, U.S. Securities and Exchange Commission, macro-prudential approach,