MFA Comment Letters

Topic: swap dealers

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 Comment Letter in Response to Basel-IOSCO’s Consultative Document on Margin Requirements for Non-Cleared Derivatives09.28.12


MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision […]

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Topics: Basel Committee on Banking Supervision International Organization of Securities Commissions, IOSCO, margin, margin requirements, non-centrally cleared derivatives transactions, Working Group on Margining Requirements, derivatives, derivatives markets, margining, clearing, market participants, central clearing, risk management, initial margin, variation margin, best practices, liquidity, mandatory clearing, bilateral exchange, buy-side firms, segregated account, custodian accounts, hedge, hedge funds, netting, eligible collateral, portfolio margining, over-collateralization, mutually offsetting transactions, margin threshold, harmonization, uniformity, non-compliance, regulatory arbitrage, market advantage, phase-in period, implementation timeline, non-cleared derivatives, regulatory authorities, foreign exchange, swaps, forwards, risk profile, market infrastructures, liquidity characteristics, currency, Denominated in G7 Currencies, G7, cleared derivatives, systemic risk, systemic importance, systemically important, systemically important non-financial firm, liquidity costs, unlevel playing field, transparency, SIFI, systemic risk level, credit, unsecured credit extension, minimum transfer amount, MTA, prudentially regulated financial counterparties, two-way margining, standard practice, credit risk, clearing house, bilateral exchange of variation margin, market liquidity, credit default swap, CDS, novation, remaining party, party stepping out, party stepping in, novating parties, market value, Regulators, novation arrangements, liquidity mechanism, asset classes, liquidation, Dodd-Frank Act, European Union, EU, United States, ISDA, International Swaps and Derivatives Association, replacement transaction, market practices, cross-product master netting agreements, risk offsets, financial instruments, U.S. Treasury futures, Eurodollar futures, non-cleared interest rate swaps, repurchase agreements, correlated financial instruments, quantitative impact study, Portfolios, central counterparty, CCP, hedged portfolios, prudential regulators, risk characteristics, risk/reward profile, diversification, concentration limits, haircuts, segregation, third-party segregation, re-hypothecation, cost mitigation, Commodity Futures Trading Commission, CFTC, swap dealers, major swap participants, equities, delta, interest rates, CDS spreads, notional value, commodities,

MFA Submits Letter to ESMA on Draft Technical Standards on OTC Derivatives08.05.12


MFA submitted a comment letter to the European Securities and Markets Authority (“ESMA”) in response to its Consultation Paper on “Draft Technical […]

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Topics: European Securities and Markets Authority ESMA, over-the-counter derivatives, OTC derivatives, CCP, trade repositories, European Parliament, Council of the European Union, OTC derivatives transactions, central counterparty, EMIR, central clearing, systemic risk, transparency, collateral, segregation, regulatory technical standards, straight-through processing, OTC derivatives market, market participants, Dealer, portability, client protections, contractual relationship, clearing member, CPSS-IOSCO, CPSS-IOSCO standards, CCP governing bodies, margin valuation, margin, risk management, risk management framework, conflicts of interest, fiduciary duty, International Organization of Securities Commissions, IOSCO, proprietary trading tools, risk committee, derivatives contracts, derivatives, risk profile, interlocking governance arrangements, trading venues, Commodity Futures Trading Commission, CFTC, Securities and Exchange Commission, SEC, internal controls, over-collateralization, in-the-money swap, "delta" hedge, swaps, credit default swap, CDS, negative correlation, capital, trading costs, credit risk, indirect clearing, non-linear products, Europe, European Union, EU, administrator, omnibus account, default, principal basis, agency basis, gross basis, net basis, LCH Clearnet, indirect client, direct client, close-out, extraterritorial application of EMIR, extraterritoriality, risk mitigation, Dodd-Frank Wall Street Reform and Consumer Protection Act, Asia, regulatory arbitrage, Regulators, counterparty risk, duplicative regulation, mutual recognition, third country regime, interpretive guidance, Cross-Border, index, foreign exchange, Euro, currency, interest rate derivatives, EU Member State, non-cleared OTC derivatives, compliance, default fund, portfolio reconciliation, portfolio compression, self-regulatory organization, SRO, swap dealers, major swap participants, Derivative Contracts, bilateral non-cleared OTC derivatives transactions, execution, hedging, upfront payment, floating rate payment, coupon, maturity, bespoke non-cleared trades, security-based swaps, debt-security based swaps, total return swaps, settlement prices, Proprietary Trading Strategy, public disclosure, confidence interval, margin requirements, financial instrument, posted collateral, interest rate swaps, Stan Ivanov, Lee Underwood, variation margin, initial margin, Basel Committee on Banking Supervision, Basel III, liquidation horizons, bilateral counterparty credit risk, netting, transaction fees, liquidity fragmentation, affiliated market participants, money market instruments, credit institutions, stress testing, back testing,

MFA Submits White Paper to European Commission on Shadow Banking06.01.12


On June 1, MFA submitted a white paper on hedge funds and shadow banking in response to the European Commission’s […]

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Topics: European Commission European Union, EU, Green Paper "Shadow Banking", shadow banking, shadow banking system, systemic risk, Background Note, Background Note "Shadow Banking: Scoping the Issues", Financial Stability Board, FSB, hedge fund industry, credit hedge funds, leverage, investor, counterparties, regulatory framework, regulatory arbitrage, financial industries, mutual funds, banks, financial market, investment strategies, asset classes, liquidity transformation, maturity transformation, risk analysis, liquidity protections, liquidity, equity investors, financial institutions, demand deposit accounts, collateral, margin, deposit-like characteristics, redemption terms, secured borrowings, direct lending, direct loan market, AIFMD, Alternative Investment Fund Managers Directive, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, originator, derivative transactions, total return swaps, secured financing, credit intermediation, non-bank financial insitutions, bank-like activities, maturity tra, G20, nonbank credit intermediation, hedge fund counterparties, broker-dealer, risk management, hidden leverage, bank-like regulation, assets under management, AUM, Securities and Exchange Commission, SEC, state securities regulators, regulatory assets under management, RAUM, U.S. Securities Laws, chief compliance officer, hedge fund managers, Form ADV, investment advisers, Form PF, Commodity Futures Trading Commission, CFTC, Financial Stability Oversight Council, FSOC, commodity futures contracts, swaps, commodity pool, commodity trading advisor, CTA, over-the-counter derivatives, OTC derivatives, central clearing, derivatives, segregation, transparency, major swap participants, swap dealers, derivatives market, Office of Financial Research, OFR, systemically important financial institution, SIFI, Board of Governors of the Federal Reserve System, the Fed, prudential regulation, Doug Elliott, Brookings Institution, absolute risk, Volcker Rule, Long Term Capital Management, "too big to fail, government insurance, market based regulations, House Financial Services Subcommittee on Financial Institutions and Consumer Credit, private equity, venture capital funds, property-casualty insurance, mutual funds management, money market funds, public company equity securities, institutional investment manager, insider trading, Department of the Treasury, Bureau of Economic Analysis, EU Member State, MiFID, Markets in Financial Instruments Directive, European Market Infrastructure Regulation, EMIR, Investment Company Institute, ICI, United Kingdom, counter-cyclical, creditor, taxpayer, sophisticated investors, instant liquidity funds, discount windows, gates, lock-up periods, side pockets, Financial Services Authority, FSA, uncollateralized loans, initial margin, variation margin, asset-backed commercial paper conduits, ABCP conduits, structured investment vehicles, SIV, Columbia University, leverage ratio, Lord Adair Turner, Hedge Fund Research, asset-backed securities, corporate bonds, government bonds, small and medium-sized enterprises, SME, leveraged loan markets, quantitative strategies, credit arbitrage strategies, fundamental credit analysis, distressed restructuring strategies, fixed income instruments, bankruptcy, private issue/Regulation D strategies, Regulation D, private investment in public equity, PIPE, relative value, pricing discrepancy, fixed income - asset backed, loans, credit cards, receivables, real estate, tangible financial commitments, fixed income - convertible arbitrage, convertible arbitrage, fixed income - corporate, corporate fixed income instrument, relative value - multi-strategies, Master Limited Partnership,

Comment Letters to Prudential Regulators on their Proposed Rules for Margin and Capital Requirements for Covered Swap Entities07.11.11


MFA submitted a comment letter to the Prudential Regulators in response to their notice of proposed rulemaking on Margin and […]

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Topics: Notice of Proposed Rulemaking on Margin and Capital Requirements for Covered Swap Entities Treasury, swap markets, central clearing, risk-based margin requirements, minimize risk, liquidity, swap dealers, SDs, major swap participants, covered swap participants, CSEs, uncleared swaps, delivery of margin, counterparties, operational costs, adverse pricing, robust netting arrangements, funding costs, customized transactions, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, unsecured counterparty credit risk, consistency, transparency, variation margin, Timothy Geithner, mandatory clearing requirements, central clearinghouse, clearing eligible, non-cash collateral, Gary Gensler, asset class, financial entity counterparties, bilateral exchange of variation margin, pension plans, university endowments, counterparty risk, systemic risk, "too big to fail, uncollaterized swap positions, indirect transmission, House Committee on Financial Services, Ben S. Bernanke, swap portfolio, risk management, cleared swap transactions, risk reduction tool, interest rate swaps, commodity swaps, FCM, credit default swap, referenced bond, interest rate swap, Eurodollar futures, security-based swaps, physically-settling forwards, repurchase agreements, security lending agreements, over-collateralization, futures commission merchant, liquidation value, cross-product netting agreements, multi-lateral netting agreements, non-cleared commodity options, paired products, trading contracts, proprietary models, equity swaps, call option, total return swap, illiquid security, ten-day liquidation time horizon, five-day time horizon, valuation formulas, swap documents, Capital Relief for Cleared Swaps, DCO, capital charge, derivatives clearing organizations, Office of the Comptroller of the Currency, Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, Farm Credit Administration, Federal Deposit Insurance Corporation, FDIC, CFTC,

Comment Letter on Proposed Rulemaking for Requirements for Processing, Clearing, and Transfer of Customer Positions04.11.11


MFA submitted a comment letter to the CFTC on its proposed rules on Requirements for Processing, Clearing, and Transfer of […]

Comment Letter to the CFTC on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants02.28.11


MFA submitted a comment letter to the CFTC on its proposal on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for […]

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Topics: Commodity Futures Trading Commission CFTC, confirmation, portfolio reconciliation, portfolio compression requirements, swap dealers, major swap participants, SDs, MSPs, operational abilities, market participants, post-trade exercises, mandated timeframes, Counterparty, trade execution, SEC, Securities and Exchange Commission, valuation data, bilateral portfolio compression exercise, multilateral portfolio compression exercises, swap markets, pre-trade draft acknowledgement requirement, customized swaps, heavily negotiated swaps, time-sensitive swaps, hedging risk, limiting parties, volatility, bid spreads, offer spreads, over-the-counter derivatives, legal risks, rights, trade acknowledgment, consistent timing, confirmation periods, financial entities, pension plans, private funds, insurance companies, banks, swap portfolio trade confirmation, electronic processing, calendar day, financial entity, trade capture system, electronic matching platforms, electronic matching process, complex swap, life cycle events, timing requirements, novation, modification, partial termination, dividend payment, merger, market disruption, compliance period, clearance, exchange execution, clearing satisfying requirements, Designated Contract Market, DCM, Swap Execution Facility, SEF, derivatives clearing organization, DCO, confirmation requirement, collateral management, counterparty risk, market risk, position level discrepancies, margin disputes, position level portfolio reconciliation, best practices, bilateral portfolio reconciliation exercise, multilateral portfolio reconciliation exercise, Valuation Disputes, valuation discrepancy, nominal value, dollar threshold, broader markets, collateral steering committee of the International Swaps and Derivatives Association Inc., ISDA, market-driven solution, portfolio compression rule, operational risk, risk mitigation benefits, multilateral compression, swaps portfolio, liquidity,

Comment Letter on Proposed Rulemaking for Systemically Significant Institutions02.25.11


MFA submitted a letter to the Financial Stability Oversight Council in response to the Councils proposed rule regarding the criteria […]