MFA Comment Letters

Topic: third country

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: CFTC Commodity Futures Trading Commission, Timothy Massad, Mark Wetjen, Scott O'Malia, Sharon Bowen, J. Christopher Giancarlo, swaps, commodity pool operators, CPO, commodity trading advisors, CTA, alternative investment strategies, Dodd-Frank Act, OTC derivatives, systemic risk, transparency, central clearing, swap execution facilities, SEF, designated contract markets, DCM, regulation, package transactions, market infrastructures, recordkeeping requirements, swap data reporting, Cross-Border, central counterparties, CCP, third country, regulatory requirements, alternative investment funds, EMIR, JOBS Act, private investment vehicles, regulatory framework, hedge fund, fund of funds, private equity fund, real estate investment trust, burdensome, CPO delegation, temporary interim relief, private funds, harmonization, no-action relief, SEC, Securities and Exchange Commission, Policy Makers, customer protection, U.S. Congress, Bankruptcy Code, futures commission merchant, FCM, legal segregation with operation commingling, LSOC, market participant, MF Global Inc., Peregrine Financial Group, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, segregated account, FCM counterparty, position limits, buy-side, straight-through processing, made available for trading, MAT, inter-dealer market, anonymity, execution, proprietary trading tools, dealer-to-customer platforms, liquidity, derivatives clearing organization, DCO, Dealer, interest rate markets, swap curves, swap butterflies, invoice spreads, swaptions, Vincent A. McGonagle, exchange for related position, EFRPs, benchmark contracts, SIFMA AMG, Asset Management Group of the Securities Industry and Financial Markets Association, Division of Swap Dealer and Intermediary Oversight, Division of Market Oversight, introducing broker, assets under management, AUM, trading privileges, commodity pool, floor brokers, Alternative Investment Management Association, AIMA, swap data repository, SDR, Commodity Markets Council, alpha swap, beta swap, gamma swap, Major Swap Participant, MSPs, European Union, EU, bespoke swaps, International Swaps and Derivatives Association, ISDA, master agreement, European Commission, OTC Derivatives Regulators Group, mandatory clearing, United States, Cayman Islands, U.S. person, swap dealer, financial counterparty, commodity interests, privately offered commodity pools, Cayman Islands Monetary Authority, British Virgin Islands Financial Services Commission, Financial Conduct Authority, Hong Kong, Securities and Futures Commission, private investment funds, limited partnership, general partner, corporations, Trust, limited liability companies, public investment fund, board of directors, chilling effect, NFA, National Futures Association, due diligence, compliance, registered investment adviser, President Obama, Obama Administration, U.S. Department of the Treasury, quarterly account statements, service providers, illiquid assets, Form PF, Form CPO-PQR, Form CTA-PR, custody rules, generally accepted accounting principles, GAAP, Form PQR, haircuts, Committee of Payment and Settlement Systems, International Organization of Securities Commissions, IOSCO, Financial Stability Board, FSB, risk management, initial margin, variation margin, loss allocation, Full Physical Segregation, customer collateral, collateral, insolvency, cleared swaps, hedgers, short, price discovery, spot-month position limits, physically settled, cash-settled contracts, natural gas, gold, silver, owned entities, passive ownership, exemptive relief, speculation, aggregation,

MFA Letter to ESAs on EMIR Risk Mitigation Regulatory Technical Standards07.14.14


MFA submitted a comment letter to the European Supervisory Authorities (ESAs) on their joint consultation paper on “Draft regulatory technical […]

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Topics: European Banking Authority European Insurance and Occupational Pension Authority, European Securities and Markets Authority, ESMA, European Supervisory Authorities, consultation paper, EMIR, European Market Infrastructure Regulation, systemic risk, counterparty credit risk, collateral, OTC derivatives market, market participants, regulatory technical standards, margin, segregation, third country, financial counterparties, non-financial counterparty, clearing threshold, variation margin, initial margin, transparency, G7, harmonization, uncleared derivative, regulatory arbitrage, Basel Committee for Banking Supervision, International Organization of Securities Commissions, IOSCO, Canada, France, Germany, Italy, Japan, United States, United Kingdom, European Commission, duplicative regulation, substituted compliance, equivalence, Cayman Islands, alternative investment funds, AIMA, Alternative Investment Management Association, European Parliament, Council of the European Union, counterparties, mandatory margin requirements, documentation, regulatory requirements, minimum notional threshold, trade repositories, settlement period, netting, trading costs, efficiency, legal opinion, verification requirement, concentration limits, proportionality principle, US Treasuries, securities, liquidity, haircuts, settlement currency, collateral currency, base currency, third party custodian, liquidation, in-scope entity, International Swaps and Derivatives Association, ISDA, dispute resolution procedures, Individual Segregation,

MFA Submits Comments on AIFMD Remuneration09.27.12


MFA submitted comments to the European Securities and Markets Authority (ESMA) on its consultation on guidelines on sound remuneration policies […]

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Topics: ESMA European Securities and Markets Authority, remuneration, consultation paper, remuneration policies, AIFMD, European Union, EU, Policy Makers, proportionality principle, AIFM, excessive risk-taking, Identified Staff, limited liability partnership, LLP, management committees, junior partner, RemCo, deferral of remuneration and pension, European Commission, Council of the European Union, European Parliament, hedge fund managers, financial institutions, deposit-taking entity, government insurance, private placement, institutional investor, sophisticated investors, bank, Insurance, alignment of interests, owner-managed AIFM, shareholders, public shareholders, third country, Regulators, carried interest, fees, service providers, commissions, delegate, performance fee, Senior Management, investors, other risk taker, risk profile, Balance Sheet, own account dealer, operational risk, United Kingdom, affiliated group, governing body, Limited Liability Company, LLC, risk management, compliance, audit, compliance staff, counsel, chief compliance officer, control functions, parent company, credit institutions, capital requirements, MiFID, MiFID firms, distributions, minimum capital requirements, management bodies, non-executive directors, hedge funds, assets under management, AUM, Member State, Member State competent authorities, control function, pension, variable remuneration, risk alignment, material risk, UCITS, performance measures, deferred remuneration, non-deferred remuneration, Claw-Back, fee structure, redemption rights, tax, Tax Implications, bonuses, underperformance, alternative instruments, retention policy, financial stability, non-EU AIFM, marketing, EU Passport, private placement regime, Disclosure, Annual Report, Confidential Information, stakeholders,

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its “Proposed Interpretive Guidance […]

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Topics: CFTC Commodity Futures Trading Commission, interpretive guidance, swaps, Alternative Investment Management Association, AIMA, financial crisis, over-the-counter derivatives, OTC derivatives, OTC derivatives market, hedge fund industry, fund of funds, hedge fund managers, prime brokers, hedge fund administrator, market participants, non-U.S. market participants, regulatory requirements, commodity pool, pooled accounts, collective investment vehicles, non-U.S. investment fund, Securities and Exchange Commission, SEC, international harmonization of regulations, regulatory framework, duplicative regulation, transaction cost, compliance costs, U.S. person, non-U.S. persons, derivatives, derivatives markets, Corporation, partnership, limited liability companies, joint-stock company, fund, pension plans, estate, Trust, income tax, Jill Sommers, Scott O'Malia, cost-benefit analysis, market impact, third country, European Securities and Markets Authority, ESMA, direct or indirect ownership, Look Through, shareholders, listed entity, foreign banks, banks, dealers, commodity pool operator, CPO, Form CPO-PQR, financial stability, financial system, chief compliance officer, risk management, swap data recordkeeping, swap data reporting, commodity swaps, clearing, swaps processing, margining, segregation, uncleared swaps, execution, portfolio reconciliation, real-time public reporting, trade confirmations, Business Conduct Standards, qualified eligible person, accredited investors, general partnerships, registration, CPO registration requirements, counterparties, swap dealer, major swap participants, MSPs, swap data repository, sell-side firms, buy-side firms, entity-level requirement, reporting party, comment letter, transaction-level requirements, majority ownership, G20, G20 commitments, substituted compliance, transparency, Policy Makers, European Parliament, Council of the European Union, Hong Kong, Hong Kong Monetary Authority, Securities and Futures Commission, Monetary Authority of Singapore, Singapore, International Organization of Securities Commissions, IOSCO, Department of the Treasury, natural person, foreign entity, Dealer, fiduciary, International Monetary Fund, International Bank for Reconstruction and Development, Inter-American Development Bank, Asian Development Bank, African Development Bank, United Nations,

MFA Response to FSA Discussion Paper on Implementation of the AIFMD03.23.12


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Topics: FSA Discussion Paper "Implementation of the Alternative Investment Fund Managers Directive" Financial Services Authority, FSA, Alternative Investment Fund Managers Directive, AIFMD, non-EU AIFM, Member State competent authorities, letter-box entity, MiFID, MiFID firm, AIFMD firm, retail customers, professional investors, remuneration provisions, CRD3 framework, functional and hierarchal independence, risk management, internationally coordinated approach to reporting, European Securities and Markets Authority, ESMA, single AIFM, family relationship, family investment vehicle, UK AIFM, preferential treatment, side letters, retail consumers, FSA Principles for Business, FCA, UCITS Directive, retail investors, EU Passport, FCA Approach Document, conflicts of interest, SYSC 10 of the FSA Handbook, remuneration guidelines, MiFID portfolio managers, tier 4 firm, FSA Remuneration Code, compliance function, audit function, proportionality principle, regulatory requirements, regulatory risks, chief compliance officer, functional and hierarchical separation, portfolio management, portfolio management personnel, interest alignment, qualitative risk limit, UCITS investors, institutional investors, leverage, NAV, third country, Final Advice on the AIFMD, third country managers, capital requirements, PII requirements, IPRU (INV), professional indemnity insurance, professional negligence, internally managed AIF, CAD-defined terms, valuation procedures, external valuer, net asset value, limited partnership, hedge funds, NAV per share, liquidity requirements, redemption terms, less than fully invested, risk/return profile, net assets under management, investor capital, Value at Risk, VaR methodology, European Central Bank, foreign exchange, interest rate risk, EUR denominated bonds, portfolio risk, hedging arragements, CESR Guidelines on Risk Management and the Calculation of Global Exposure and Coutnerparty Risk for UCITS, CDS, Advanced Method, QIS disclosure requirements, prime brokers, exchanges, swap data warehouses, Dodd-Frank Act, Securities and Exchange Commission, SEC, Form PF, proprietary business information, depositary, unregulated CIS, segregated account, valuation oversight duties, depositary liability, marketing, reverse solicitation process, MiFID investment services, private placement, public offers,