MFA Comment Letters

Topic: short positions

MFA and AIMA Submit Joint Letter to ESMA in Response to Call for Evidence on Short Selling Regulation03.15.13


MFA and AIMA jointly submitted a comment letter to ESMA responding to its Call for Evidence regarding its evaluation of […]

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Topics: ESMA European Securities and Markets Authority, AIMA, Alternative Investment Management Association, European Parliament, Council of the European Union, short selling, credit default swap, CDS, short selling regulation, Europe, equity, assets under management, AUM, harmonization, competent authorities, reporting requirements, short positions, European Commission, operational challenges, short selling bans, market participants, securities, sovereign issuer, capital, liquidity, price discovery, market distortions, hedging, risk, sovereign debt, Latvia, bond, sovereign bonds, EU Member State, futures, futures market, public disclosure, stock, reverse engineer, efficiency, short squeeze, volatility, reporting obligation, T+1 reporting, hedge funds, price formation, corporate issuer, Lehman Brothers, duration, delta, derivatives, share capital, index derivatives, AIFMD, MiFID, EMIR, net short position, Belgium, Finland, Germany, Netherlands, BaFin, United Kingdom, Commissione Nazionale per le Societa e la Borsa, Committee of European Securities Regulators, CESR, issued share capital, T+2, Bundesanstalt fur Finanzdienstleistungsaufsicht, settlement, locate, prime broker, index, third party managers, technical standards, non-EU investment firms, extraterritoriality, reasonable expectation, uncovered sovereign CDS, eurozone, mark-to-market, single-name CDS, France, Spain, Italy, trading volume, Steven Maijoor, bid-ask spreads, price efficiency, derivative instrument, depositary receipts, London Stock Exchange, PRNewswire, Stock Exchange Daily Official List, compliance, market disruption, interpretive guidance,

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

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Topics: private funds commodity pool operators, commodity trading advisors, Form PF, systemic risk, Financial Stability Oversight Council, market participants, managed futures, absolute return strategies, SEC, CFTC, Dodd-Frank Act, Council and Office of Financial Research, OFR, global regulators, overcounting, undercounting, threshold for enhanced performance, assets under management, reporting period, confidentiality protections, inadvertent disclosure, non-bank financial companies, lending institutions, interconnectedness, liquidity risk, maturity mismatch, regulatory scrutiny, systemically significant, Federal Reserve System, the Fed, Form CPO, Form PQR, Form CTA-PR, targeted requests, tiered reporting system, threshold, trading and investment strategies, borrowing arrangements, collateral practices, operational capabilities, illiquid assets, investment advisers, bespoke contracts, private equity, privately issued convertible bonds, equity derivatives, distressed debt, unaffiliated third party sources, generally accepted accounting principles, GAAP, Level 2 inputs, Level 3 inputs, Financial Accounting Standards Board, audited financial statements, UK Financial Services Authority, FSA, Form 13F, public companies, Form 10-K, Form 10-Q, portfolio management, CUSIP number, semi-annual reporting, counterparty exposures, market noise, short-term market fluctuations, margin requirements, hedge fund defaults, large private fund manager, qualifying fund, hedge fund assets under management, Form ADV, proposed reporting thresholds, interpretive guidance, private fund managers, recordkeeping requirements, section 404, confidentiality of information, proprietary information, Investment Adviser Registration Depository, Schedule 13G, individual certification, valuation methodology, proprietary methodology, alternative methodology, de minimis, master-feeder, parallel funds, equity prices, interest rates, currency rates, Form PF question 36, form PF questions 28 and 35, funds of funds, direct investments, aggregate gross asset value, collateral, operational efficiency, ten-year option, five-year option, master agreement, regulatory assets under management, net assets under management, leverage, parallel managed accounts, net asset value, gross asset value, creditor, net borrowings, aggregate borrowings, beneficial owners, record owners, fixed advisory fees, investment expenses, performance fees, inception class, statistical arbitrage-equity, other quantitative strategies, strategy exposure, risk capital allocation, NAV, futures commission merchants, FCMs, direct clearing members, DCMs, prime brokers, clause (iii), loan commitments, offsetting exposure, tri-party collateral accounts, market value, asset-backed securities, debt securities, swap contracts, futures contracts, foreign currency contracts, notional value of derivatives, notional amount, long positions, short positions, LMV, SMV, maturity brackets, short-term interest rate, DV01, CR01, duration, non-rated issues, short term high quality corporate debt, foreign exchange derivatives, turnover rate, GMV, Bloomberg, risk methodology, repos, sensitivity analyses, liquidity management, balance sheet value, delta adjusted, variation margin, equity exposure, rehypothecated initial margin, CCPs, central clearing counterparties, Value at Risk, VaR, CDS, CDX, default rates, corporate bonds, short borrowing, synthetic borrowing, uncommitted lines of credit, side pocket arrangement,

Comment Letter to the CFTC in Response to its Request for Comments on Position Limits for Derivatives03.28.11


MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains […]

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Topics: CFTC Commodity Futures Trading Commission, position limits, derivatives, futures, option contract, swap contract, futures market, price risk, commercial participants, operating company, financial institution, energy market infrastructure, liquid price discovery, risk-shifting market, market manipulation, federal limits, crowding out provision, spot month, disaggregation relief, deliverable supply, inter-commodity spread transactions, bona fide hedger, price discovery, risk management, commodity market, annual recalculation methodology, U.S. futures exchange, delivery point, individual class rules, legacy position limits, agricultural commodities, disorderly markets, spot-month position limits, referenced contracts, aggregate spot-month position limits, swaptions, DCMs, physically delivered contracts, cash-settled contracts, conditional-spot month limit, cash position, forward position, physical commodity deliverable, aggregate all-months-combined, aggregate single-month, futures class all-months-combined, futures class single-month, swaps class all-months-combined, swaps class single-month, open interest, non-spot position limits, calendar-spread exemption, hedging transaction, cash market transaction, cash market risk, swap dealer hedge exemption, pool participant, future commission merchants, FCMs, independently controlled and managed trader, account aggregation requirements, enumerated agricultural commodities, open interest formula, position visibility, reporting requirements, offsetting positions, excessive speculation, interstate commerce, physical commodity, interest rates, stock indices, squeezes, market liquidity, global commodity, regulatory oversight, risk transfer, energy price volatility, CTFC Inter-Agency Task Force on Commodity Markets, GAO, IOSCO, IMG, UK Treasury, CME, The Economist, supply and demand, U.S. dollar, price volatility, NYMEX crude oil price, speculative investment, crude oil futures, International Organization of Securities Commission, IOSCO Technical Committee, IMF World Economic outlook, HM Treasury Global Commodities, OECD publishing, JP Morgan, long positions, hedge funds, short positions, Chicago onions, Berlin wheat, Credit Agricole, Energy Risk, University of Calgary, PKVerleger LLC, Wall St. Journal, Artificial limits, Barclays Capital, OECD Food, Jacks Study, Commission Energy Complex Report, Global Energy Management Institute, Bauer College of Business, University of Houston, House Committee on Agriculture, Pirrong Testimony, price spikes, agricultural model, metal commodity, seasonal variation, market surveillance, OTC, WTI, independently controlled accounts, independent third party, commodity trading advisors, common parent, CPO, CTA, control standard, commodity pool operator, commodity trading advisor, eligible entity, order routing arrangement, disclosure documents, non-financial entity exemption, active trading program, passive trading program, funds of funds, private equity investments, passive investors, pension plan, independent account controller exemption, asset manager, corporate enterprises, speculative trading ventures, CFTC docket no. 11-05, CFTC docket no. 08-02, pool participant exemption, equity interest, market depth, no-action relief, percentage interest, real-time basis, university endowment, liquidity provisions, application based exemption, approval based exemption, annual renewal based exemption, self-executing disaggregation, reporting obligation, surveillance, audit, enforcement, cross-ownership of traders, statement of reporting trader, benchmark contracts, NYMEX Henery Hub Natural Gas contract, commercial hedgers, inter-commodity spread exemption, arbitrage exemption, directional position, outright positions, submarket, large trader data, seasonality, annual limits, CBOT, NYBOT, KCBOT, pre-existing position exemption, significant price discovery contracts, index fund manager, class limits, rounding, hypothetical portfolios, cleared bilateral contracts, non-cleared bilateral contracts, front month position, deferred month positions, last day swaps, penultimate swaps, options, delta, financial cal spread options, physical cal spread options, physical options, HH natural gas,

MFA Comments on Consultation on Increasing Short Position Transparency10.09.09


MFA submitted a letter to the Hong Kong Securities and Futures Commission (SFC) today in response to its Consultation Paper […]

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Topics: Securities and Futures Commission SFC, short positions, Hong Kong, manipulative conduct, short selling, efficiency, liquidity, public disclosure of short positions, price discovery, risk management, financial stocks, net long position, financial services sector, non-public disclosure, confidentiality, market participants, anonymised disclosure, short selling bans, global equity markets, bid-ask spreads, short sellers, short selling disclosure regime, transparency, cash markets, close out indicators, on-market transactions, derivatives, exchange trading, off-exchange transaction, hedging strategies, stocks, delta adjusted, designated securities, listed corporations, non-designated securities, OTC transaction, dual-listed securities, CESR, pan-European short selling disclosure regime, primary market, Hong Kong market, net short positions, transitory short position, reporting threshold, FSA, Financial Services Authority, Securities and Exchange Commission, SEC, turnover ratio, price volatility, capital raising, settlement, SEHK, market volatility, investment managers, private reporting, chilling effect, market efficiency, price formation, short squeeze, herding, volatility, institutional investors, retail investors, transaction costs, alternative investment classes, pensions, endowments, foundations, market liquidity, capital formation, convertible arbitrage, convertible bonds, copycat behavior, proprietary research, market making, Journal of Finance,

MFA Response to CESR Consultation Paper on a Proposal for a Pan-European Short Selling Disclosure Regime10.01.09


MFA submitted a letter to the Committee of European Securities Regulators (CESR) today in response to its Consultation Paper on a […]

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Topics: Committee of European Securities Regulators CESR, CESR Proposal for a Pan-European Short Selling Disclosure Regime, alternative investment managers, hedge funds, fund of funds, hybrid funds, 130/30 funds, managed futures funds, industry service providers, alternative investment industry, absolute return strategies, short selling, manipulative conduct, Market Confidence, stability, public disclosure of short positions, short positions, market volatility, price discovery, risk management, risk management function, significant adverse effect, financial services sector, investors, Issuer, market participants, de minimis, aggregated anonymised data, timeframe for reporting, transparency directive, meaningful data, short selling bans, global equity markets, academics, liquidity, bid-ask spread, price declines, materially negative impacts, market efficiency, short selling disclosure regime, equity markets, enhanced transparency, investment managers, abusive short selling practices, abusive practices, financial institutions, herding, institutional investors, retail investors, transaction costs, capital markets, free flow of information, chilling effect, alternative investment classes, Pension Funds, endowments, foundations, alternative investment vehicles, hedging strategies, capital formation, hedge, convertible arbitrage, short equity position, convertible bonds, traditional bond issuance, convertible securities, short squeeze, Reverse Engineered, trading strategies, long equity positions, exposures, Unwind, financial stocks, pricing efficiency, short selling prohibitions, European markets, large-scale short selling, extreme market conditions, negative returns, UK Financial Services Authority, FSA, securities prices, naked short selling, Journal of Finance, Credit Suisse, market stability, disclosure thresholds, private reporting, flagging short sales, Financial Regulatory Authority, FINRA, flagging regime, disproportionate costs, real time information, over-the-counter transactions, exchanges, trading platform, settlement, physical short sales transactions, EEA stock, extraterritoriality, European Union, EU, EEA equities, two-tier disclosure model, price amplification, market testing, MiFID, competent authorities, Member State competent authorities, professional secrecy, confidentiality, freedom of information regimes, harmonization, net economic short positions, transitory short position, abusive behavior, share issues, capital raising, index trading, basket trade, reporting regimes, net economic short position, asset management company, aggregation, prudential regulators, T+1 reporting, derivatives, derivative positions, delta adjusted, cumulative compliance costs, global capital markets, EU Member State, market maker, market making,

MFA Letter to UK Financial Services Authority to Proposed Short Selling Disclosure Measures05.08.09


MFA submitted a letter to the U.K. Financial Services Authority in response to its proposed short selling disclosure measures, recommending […]