MFA Comment Letters

Topic: Swap Execution Facility

MFA Submits Letter to ESMA on Straight-Through-Processing08.05.12


On August 5, MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) to advocate for the […]

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Topics: ESMA European Securities and Markets Authority, OTC derivatives, CCP, trade repositories, straight-through processing, regulatory technical standards, EMIR, over-the-counter derivatives, derivatives, European Parliament, Council of the European Union, OTC derivatives transactions, central counterparty, systemic risk, counterparty credit risk, credit risk, market access, efficiency, operational market processes, clearing, execution, executing counterparty, market participants, clearing obligation, documentation, clearing member, interest rate swap, credit default swap, CDS, CME, Chicago mercantile exchange, alternative liquidity providers, liquidity, risk, electronic trading, bilateral derivatives transactions, bilateral master agreements, risk management, real-time processing, Commodity Futures Trading Commission, CFTC, Designated Contract Market, DCM, Swap Execution Facility, SEF, execution platform, Allocations, cost-benefit analysis, European Union, EU, ESMA Task Forces, transparency, OTC Derivatives Task Force, CCP Requirements Task Force, Trade Repositories Task Force, derivatives transactions, international harmonization of regulations, Financial Stability Board, FSB, European Commission, delegated acts, customer clearing documentation, directive, due diligence, operational risk, Court of Justice of the European Union, Continental Cans, EU Member State, Commission v. Council ERTA, financial stability, Christopher Seagon v. Deko Marty Belgium NV, clearing agreement, financial system, United States, Dodd-Frank Act, real-time acceptance, competition, settlement, liquidity fragmentation, central limit order books, International Swaps and Dealers Association, ISDA, bid-ask spread, limit check, trading venues, credit intermediation, derivatives markets, bilateral risk management, volatility, derivatives clearing organization, DCO, swap dealer, Major Swap Participant, dealer-to-dealer clearing, dealer-to-customer platforms, mandatory clearing, clearinghouse, bilateral credit agreement, bilateral market, competitive liquidity, block transactions, investment managers, breakage, Futures Industry Association, FIA, trading desk, anti-competitive effects, ICE energy swaps, ICE Clear Credit LLC, LCH Clearnet, clearing acceptance process, trilateral documentation, designation notice, Managed Funds Association, bundled trade, futures, futures market, credit limit order bookc, credit limit, interconnectedness, dealers, real economy, pension fund, endowments, institutional investors, Liquidity Providers, trilateral clearing agreements, energy derivatives, technical standards, voice execution, matched transactions, direct clearing members, credit limits, risk-based, latency, transaction capture facility, anti-competitive restrictions, aggregate limit, underlying clients,

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 on Proposed Rule and Interpretation on Registration and Regulation of Security Based Swap Execution Facilities04.04.11


MFA submitted a comment letter to the SEC on its proposed rule and proposed interpretation on Registration and Regulation of […]

Comment Letter to the CFTC on its Proposed Rules on Risk Management Requirements for Derivatives Clearing Organizations03.21.11


MFA submitted a comment letter to the CFTC on its proposed rules on Risk Management Requirements for Derivatives Clearing Organizations. […]

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Topics: Commodity Futures Trading Commission CFTC, Risk Management Requirements, derivatives clearing organizations, DCO, participant eligibility, eligibility standards, fair and open access, clearing member, DCO concentration risk, diversity of market participants, competition, capital requirements, clearinghouses, swap portfolio size, transaction volume, antitrust considerations, $50 million upper limit, minimum capital requirements, net capital obligation, risk exposure, risk-based methodologies, stress and default scenarios, tiers, threshold guaranty fund contribution, direct clearing members, DCO margin methodologies, guaranty fund scaling methodologies, margin, obligations, cleared trade volumes, scaling requirements, Chicago Board of Trade, committee on payment and settlement systems and technical committee of the International Organization of Securities Commissions, CPSS-IOSCO standards, product eligibility, Designated Contract Market, DCM, Swap Execution Facility, SEF, electronic execution, connectivity, standard two-way protocols, executing counterparty, risk management, margin requirements, market liquidity, initial margin, five-day liquidation horizon, highly liquid instruments, market volatility, on-the-run 10 year interest rate swaps, initial margin requirements, excess margin, default management framework, customer initial margin, direct clearing members' initial margin, credit risk, Columbia University, leverage ratio, investment banks, hedge fund industry, non-hedge positions, product portfolio, swap portfolio, margin methodology, creditworthiness, counterparty credit assessment practices, margin calls, mark-to-market variations, volatility, bilateral trades, greater market concentration, systemic risk mitigation, Bank of America-Merrill Lynch, The Turner Review, global banking crisis, margin calculation utility, effective date, phase-in period, mandatory central clearing, differentiated margining, portfolio margining, cross product margin, swaps, futures, federal register, Federal Reserve Bank of New York, ISDA, SEC, Securities and Exchange Commission,