MFA Comment Letters

Topic: Securities Industry and Financial Markets Association

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 Amicus Brief on Issue of Creditor Coordination06.29.12


On June 29, MFA filed an amicus brief in the 11th Circuit en banc review of the CompuCredit case.  At […]

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Topics: U.S. Court of Appeals for the Eleventh Circuit Compucredit Holdings Corporation v. Akanthos Capital Management LLC, Loan Syndications and Trading Association, Securities Industry and Financial Markets Association, SIFMA, Moses Silverman, Aidan Synnott, Daniel Crane, Financial Crisis Inquiry Commission, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, FDIC, Office of the Comptroller of the Currency, Edward Altman, Brendy Kuehne, New York University Salomon Center, Stern School of Business, John Coffee Jr., William Klein, Conrad Duberstein, Tomotaka Fujita, Marcel Kahan, corporate bonds, Michael MacKenzie, Nicole Bullock, Glenn Merrick, Ali Stoeppelwerth, banks, investment banks, broker-dealer, alternative investment industry, securities firms, capital formation, chilling effect, borrowers, distressed debt, contractual relationship, interest rates, creditor, credit squeeze, credit market, bonds, secondary loan markets, institutional lender, leverage, systemic risk, Shared National Credit Review, syndicated loan market, Bondholder, maturity date, debtor, Bankruptcy Filing, Bankruptcy Code, collective action risks, capital, primary market, risk portfolio, U.S. Court of Appeals for the Seventh Circuit, Judge Easterbrook, U.S. Court of Appeals for the Second Circuit, price-fixing, hedge funds, price competition, contract, bilateral monopoly, per se rules, par value, debt instruments, high-velocity market, low-velocity market, creditor coordination, market power, anticompetitive, competition, pre-packaged bankruptcy, Broad. Music Inc. v. Columbia Broadcasting Sys. Inc, Bus. Elecs. Corp. v. Sharp Elecs. Corp., Classic Cheesecake Co. Inc. v. JPMorgan Chase Bank NA, Falstaff Brewing Corp. v. New York Life Ins. Co., Federal Trade Commission v. Brown Shoe Co., Federal Trade Commission v. Indiana Federation of Dentists, Federal Trade Commission v. Superior Court Trial Lawyers Association, Finnegan v. Campeau Corp., United States v. Giordano, Ireland v. Craggs, Leegin Creative Leather Products Inc. v. PSKS Inc., Arizona v. Maricopa County Medical Society, Maris Distrib. Co. v. Anheuser-Busch Inc., National Collegiate Athletic Association v. Board of Regents, Northwest Wholesale Stationers Inc. v. Pacific Stationery & Printing Co., Palmyra Park Hosp. Inc. v. Phoebe Putney Memorial Hospital, Reisner v. General Motors Corp., Reiter v. Sonotone Corp., Sharon Steel Corp. v. Chase Manhattan Bank NA, Smith v. The Ferncliff, State Farm Mutual Auto. Ins. Co. v. Physicians Injury Care Center Inc., United States v. Topco Assocs Inc., Twin City Pipe Line Co. v. Harding Glass Co., Unijax Inc. v. Champion International Inc., United Airlines Inc. v. U.S. Bank NA, Volt Info. Scis. Inc. v. Board of Trs. of Leland Stanford Jr. University,

MFA and Associations File Amicus Curiae Brief in RadLAX Gateway v. Amalgamated Bank Case Before U.S. Supreme Court03.09.12


MFA, with the Loan Syndications and Trading Association, SIFMA, and seven other trade associations submitted an amicus brief in the […]

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Topics: RadLAX Gateway Hotel LLC and RadLAX Gateway Deck LLC v Amagamated Bank write of certiorari, Mortgage Bankers Association, Securities Industry and Financial Markets Association, Loan Syndications and Trading Association, American Bankers Association, Clearing House Association, Commercial Finance Association, Equipment Leasing and Finance Association, Financial Services Roundtable, Elliot Ganz, Seth P. Waxman, Craig Goldblatt, Danielle Spinelli, Eric F. Citron, Shivaprasad Nagaraj, secured creditors, credit-bid, free-and-clear sale, secured credit, amici curiae, trade associations, corporate and commercial loans, mortgage-backed financing, asset-backed financing, private investment fund, borrowers, investment banks, manufacturers, hedge funds, funds of funds, managed futures funds, real-estate finance industry, chapter 11 plan of reorganization, collateral, undervaluation, secured financing, lien, fair and equitable, indubitable equivalent, stalking-horse bidder, Bankruptcy Code, secured creditor, cram-down, non-consenting class of secured creditors, speedy-trial deadline, statutory surplusage, consenual plans, nonconsensual free-and-clear sale, bankruptcy law, cash out, Judge Hand, clear and manifest contrary intention, Justice Brandeis, transfer, sale, sale exception, inconsequential value, valuation, present value, favored bidders, old equity, existing management, bankruptcy estate, available bidders, bidder, white knight bidders, commercial real-estate loans, commercial mortgage-backed securities, CMBS, real estate mortgage investment conduits, REMICs, BFP v. Resolution Trust Corp., Bloate v. United States, Bank of America National Trust & Savings Association v. 203 North LaSalle St. Partnership, D. Ginsberg & Sons Inc. v. Popkin, Dewsnup v. Timm, Duncan v. Walker, Dynamics Corp. of America v. CTS Corp., Easton v. German-American Bank, In re Beker Industries Corp., In re California Hancock Inc., In re FCX Inc., In re Murel Holding Corp., In re Philadelphia Newspapers LLC, In re River East Plaza LLC, In re Yale Express System Inc., Louisville Joint Stock Land Bank v. Radford, Pacific Gas & Electric Co. v. California ex rel. California Department of Toxic Substances Control, Sage v. Central Railroad Co., Toibb v. Radloff, W.B. Worthen Co. v. Kavanaugh, Wright v. Vinton Branch of Mountain Trust Bank,

Supplementary Letter to the SEC in Response to its Proposed Antifraud Rule with Respect to Security-Based Swaps03.29.11


MFA submitted a letter to supplement our December 23, 2010 letter to the SEC in response to its proposed antifraud […]

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Topics: Securities and Exchange Commission SEC, Fraud, Manipulation, Deception, security-based swaps, anti-fraud rule, security based swaps market, cost-benefit analysis, honest markets, legitimate market activity, US OTC derivatives market, derivatives market, swaps market, legitimate market participation, purchase, sale, definitions, statutory authorization, security based swap anti-fraud rule, Securities Industry and Financial Markets Association, International Swaps and Derivatives Association Inc, The Loan Syndications and Trading Association, maturity date, context, bilateral contracts, novations, unwinds, assignments, execution, termination, assignment, exchange, transfer of rights/obligations, conveyance of rights/obligations, extinguishment of rights/obligations, total return swaps, credit default swaps, transferor, credit events, corporate actions, underlying shares, disruption events, termination events, collateral, systemic risk, interim payments, premium payments, spread payments, material non-public information, ISDA master agreement, clearing agreement, counterparty defaults, bankruptcy proceedings, Bankruptcy Code, automatic stay provisions, price discovery process, fair dealing, competition, capital formation, Financial Crisis Inquiry Commission, single name credit default swaps, non-index multi-name credit default swaps, equity linked forwards, equity-linked swaps, unallocated swaps, Bank of International Settlements, BIS, price discovery, primary participant, secondary participant, credit exposure, equity exposure, institutional leveraged loans, investment grade bonds, Financial Stability Board, primary debt issuance, investment grade loans, leveraged loans, LBO-related loans, corporate loans, high yield bonds, Loan market Review, Reuters, SEC v. Rotech, FCIC, CDS market, swap market, financial crisis, price efficiency, investor confidence, material dislocation,