MFA Comment Letters

Topic: SIFMA

MFA, ICI & SIFMA Order Routing Disclosure Template Recommendation to SEC10.23.14


On October 23, MFA, ICI and SIFMA submitted a letter and order routing disclosure template to Chair White for the […]

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 Files Amicus in Lehman Litigation to Support Judicial Asset Sale Process09.28.12


MFA filed an amicus brief in the Barclays Capital and LBI SIPA Trustee litigation before the Second Circuit Court of […]

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Topics: amicus brief U.S. Court of Appeals for the Second Circuit, Lehman Brothers Holding Inc., Barclays Capital, James W. Giddens, Securities Investor Protection Corporation Trustee, amicus curiae, capital markets, no-cash deal, bankruptcy, Bankruptcy Code, Acton v. Fullmer (In re Fullmer), Adelphia Recovery Trust v. HSBC Bank USA (in re Adelphia Recovery Trust), Bass v. Parsons (In re Parsons), Big Shanty Land Corp. v. Comer Props. Inc., Folger Adam Security Inc. v. Dematteis/MacGregor, In re Cavalieri, In re Cedar Tide Corp, In re F.A. Potts & Co., In re Fehl, In re Gulf Coast Oil Corp., In re Integrated Res. Inc., In re Sapolin Paints Inc., In re Savage Indus. Inc., In re Silver Bros. Co., In re Smith, In re Weisser Eyecare Inc., M.R.R. Traders Inc. v. Cave Atlantique, Matter of Pease, Med. Malpractice Ins. Ass'n v. Hirsch (In re Lavigne), Meinwald v. Meinwald, Morgan Olson LLC v. Federico et al. (In re Grumman Olson Indus. Inc.), United States v. Sforza, Walker v. Lee (in re Rounds), Winston Inn & Rest. Corp. v. DeMichiel (In re Winston Inn & Rest. Corp.), Rob Copeland, Kelly DePonte, Financier Worldwide, Adam Levitin, Richard Mikels, Ella Shenhav, SIFMA, Illinois, Managed Funds Association, MFA, public policy, alternative investment industry, best practices, pensions, endowments, institutional investors, risk management, Australia, Europe, Asia, assets under management, AUM, bankruptcy court, transparency, contract, stakeholders, Clarification Letter, Lehman Margin Cash, purchaser, LBHI, Lori Fife, Harvey Miller, borrowers, lenders, secondary offerings, liquidity, interest rates, debtor, United States Bankruptcy Court for the Southern District of New York, free and clear, banks, New York Adelphia, litigant,

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,

Comment Letter to the CFTC on its Proposed Core Principles and Other Requirements for Swap Execution Facilities03.08.11


MFA submitted a comment letter to the CFTC on its proposed Core Principles and Other Requirements for Swap Execution Facilities. […]

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Topics: Commodity Futures Trading Commission CFTC, swap execution facilities, SEFs, SEF trading platforms, regulatory efficiencies, market efficiencies, market-based competition, transparency, real-time public reporting of swap transaction data, available for trading, competition, grandfather relief, request for quote, RFQ, order book, cleared swaps, block trades, timing delay, required transactions, Designated Contract Market, DCM, Mandatory Execution Requirement, annual review, market liquidity, minimum block threshold, large notional transaction size threshold, reporting requirements, recordkeeping requirements, daily trading records requirements, major swap participants, CEA, RFQ system, Over-the-Counter, OTC, electronic platform, one-to-one voice services, mandatory objective criteria, mandatory transparent criteria, OTC market, connectivity, grace period, liquidity, resting bids, swap data repositories, liquidity characteristics, bilateral trading environment, trading venues, dealer-to-customer platforms, exchanges, swap execution, bilateral trading, voice-based trading, flexibility, execution protocol, order book systems, multiple-to-multiple trading venues, limit order, central limit order variants, non-continuous liquidity, credit default swaps, responsive quote, interstate commerce, mandatory minimum required recipients, quote requesters, institutional investors, voice-based system, security-based swap execution facility, SB SEF, permitted transactions, block trade thresholds, block size, data analysis, minimum block sizes, joint the trade, auction-based methods, matching, fixing, open outcry trading pits, quote-requesting participant, widened bid/offer spreads, exchanges for physical, exchanges for swaps, off-market transactions, linked transactions, packaged transactions, single joint transactions, crossing, matching traders, futures position, physical position, cash position, debt instrument, physical contract, discreet contract, Manipulation, price distortion, congestion, sporadic liquidity, emergency procedure, public information, complete audit trail, conflicts of interest, chief compliance officer, ISDA, SIFMA, Over-the-Counter Derivatives Markets, CBOE futures exchange, RFQ response period, Rulebook,