MFA Comment Letters

Topic: synthetic exposure

MFA Submits Letter to IRS on Proposed Rules on Dividend Equivalent Payments04.06.12


MFA submitted a comment letter to the Internal Revenue Service on the IRS proposed rules under Section 871(m) of the […]

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Topics: Internal Revenue Service IRS, dividend equivalent, tax avoidance, market participants, contractual representations, undue market disruption, swaps, delta-one instruments, customized index, derivatives, equity linked derivatives markets, in connection with standard, in the market, crossing transactions, short-term trades, high-frequency trading, gross witholding, cascading witholding taxes, special dividends, witholding agent, FATCA, specified notional principal contracts, SNPC, outstanding positions, dividend equivalent payments, abusive practices, non-U.S. persons, out-of-the-money, equity-linked swaps, options, futures, underlying security, strike price, dividend payment, dividend swaps, long-party, short-party, future dividend flow, anti-abuse rule, delta-one, International Swaps and Dealers Association, ISDA, delta, delta one instrument, non-delta one instrument, 90-Day Rule, retested, market forces, broad-based indices, market sector, credit, leverage, trading strategies, recognized independent index publisher, options contracts, proprietary index, preferred stock, common stock, illiquid securities, derivatives transactions, private funds, public float, hedge, synthetic exposure, offsetting position, individual trade determinations, investment algorithms, compliance restrictions, long equity swap, investment fund, single strategy fund, multi-strategy fund, average daily trading volume, ADTV, public float test, Bloomberg, direct or indirect "cross", crossing, full notional amount, internal tax review system, real-time identification of offsetting positions, 30 day liquidity, Department of the Treasury, overwitholding, extraordinary dividend, Options Clearing Corporation, OCC, ordinary divident, special dividend, OTC option, options market,

Comment Letter to SEC and CFTC on Proposed Rules Defining ‘Swap,’ ‘Security-Based Swap,’ and ‘Security-Based Swap Agreement,’ and Guidance on Mixed Swaps and Security-Based Swap Agreement Recordkeeping07.22.11


MFA submitted comments to the SEC and CFTC in response to their request for comments on their proposal on the […]

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Topics: Commodity Futures Trading Commission CFTC, Securities and Exchange Commission, SEC, further definitions of swap, Security-Based Swap, security-based swap agreement, mixed swaps, security-based swap agreement recordkeeping, forward contract exclusion, commodities, 1993 energy exemption, loan participants, OTC derivatives, systemic risk, book-out contracts, market participants, nonfinancial commodity, security, deferred shipment, delivery, physically settled, physical commodity, energy commodities, oil, alternative delivery procedures, loan participations, direct or indirect ownership, beneficial ownership interest, true participation, Federal Securities Laws, netting, loan markets, participation agreements, assignment and assumption agreements, grantor, participant, Loan Syndications and Trading Association, LSTA, loan market association, LMA, lender of record, loan agreement, loan payments, true sale, bankruptcy estate, current debtor-creditor relationship, true participants, loan total return swaps, total return receiver, total return payer, reference loan, synthetic exposure, loan transfer mechanism, primary loan markets, secondary loan markets, exchange trading, central clearing, capital, margin, reporting, recordkeeping, business conduct requirements, eligible contract participants, material non-public information, private market, antifraud liabilities, loan arrangers, alternative transfer structure, syndicated loan market, institutional investors, liquidity, U.S. domiciled counterparties, non-U.S. counterparties,
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