MFA Comment Letters

Topic: trading costs

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 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 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 Comments to the Monetary Authority of Singapore on Proposed Regulations on OTC Derivatives03.26.12


MFA submitted a comment letter to the Monetary Authority of Singapore (MAS) in response to its Consultation Paper on Proposed […]

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Topics: Monetary Authority of Singapore MAS, OTC derivatives, over-the-counter derivatives, Consultation Paper on Proposed Regulation of OTC Derivatives, G20, OTC derivatives market, systemic risk, efficient capital flows, mandary clearing, clearing, bilateral market, risk management, derivatives transactions, trading mandate, liquid and standardized transactions, client access to clearing, clearing arrangements, margin methodologies, straight-through processing, central clearing, Commodity Futures Trading Commission, CFTC, Gary Gensler, Securities and Exchange Commission, Mary Schapiro, market participants, central counterparty, CCP, average notional value, clearing threshold, buy-side clearing, U.S. Federal Reserve Bank of New York, Dodd-Frank Wall Street Reform and Consumer Protection Act, Dodd-Frank Act, backloading, Financial Stability Board, FSB, international harmonization of regulations, swaps, European Union, EU, European Commission, ESMA, legal entity identifiers, confidentiality, transaction data, counterparty identification, customized and proprietary investment strategies, intellectual property, International Organization of Securities Commissions, IOSCO, foreign regulator, financial entities, non-financial entities, Singapore, Form PF, margin requirements, netting, trading costs, aggregate counterparty credit risk, settlement risk, commercial banks, dealers, money changers, registered insurers, non-centrally cleared derivatives transactions, margin determinations, liquidation horizons, fragmentation of liquidity, clearing house, counterparty risk, recognized clearing houses, clearing facilities, real-time processing, barriers to entry, non-dealer client representation, risk committees, G20 commitments, regulatory regime, duplicative regulation, U.S. Senate Committee on Agriculture Nutrition and Forestry, trade repositories, Securities and Futures Commission, Honk Kong Monetary Authority,

Comment Letter to CFTC on Proposed Rules Governing Protection of Cleared Swap Customer Contracts and Collateral08.08.11


MFA submitted a comment letter to the CFTC in response to its notice of proposed rulemaking on Protection of Cleared […]

Comment Letter on Proposed Rules for Margin Requirements for Uncleared Swaps and Capital Requirements for Swap Dealers and Major Swap Participants07.11.11


MFA submitted a comment letter to the CFTC in response to both their notice of proposed rulemaking on Capital Requirements […]

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Topics: Commodity Futures Trading Commission CFTC, "Proposed Capital Rules, " "Proposed Margin Rules, margin, liquidity, swap markets, prudential regulator, CSE, buy-side firms, central clearing, uncleared swaps, customized transactions, unsecured counterparty credit risk, transparency, margin practices, two-way exchange of variation margin, netting, safeguards. designated clearing organization, DCO, Timothy Geithner, Gary Gensler, counterparties, trading costs, adverse pricing, funding costs, variation margin, collateral management practices, financial entities, non-cash collateral, Office of the Currency, Office of the Treasury, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, Farm Credit Administration, Federal Housing Finance Agency, systemic risk, shielding assets, pension plans, university endowments, bilateral variation margin exchange, unsecured obligations, one-sided variation margin arrangements, SEC, "too big to fail, " uncollateralized swap positions, margin exchange, swap portfolio, counterparty credit quality, Hon. Ben S. Bernanke, risk management, asset classes, interest rate swaps, commodity swaps, equity swaps, referenced bond, Eurodollar futures, physically-settling forwards, repurchase agreements, security lending agreements, liened account assets, initial margin model, portfolio offsets, Alternative Method, net counterparty exposure, out-of-the-money swap, in-the-money swap, initial and variation margin transfers, futures commission merchant, asset class, multi-lateral agreements, cross-product netting agreements, non-cleared commodity options, liquidation value, paired products, trading contracts, capital planning, multiplier of 2.0, multiplier of 4.4, reference cleared swap, grid-based method, proprietary models, ten-day liquidation time horizon, five-day time horizon, segregation of customer assets, custodian, Capital Rules, capital requirements, Mr. Eric Chern, Chicago Trading Company, Joint Commission-SEC Staff Roundtable on Proposed Dealer and major Participant Definitions Under the Dodd-Frank Act, tailored products, Reporting of Capital Requirements, collateral delivery, counterparty exposure, Capital Relief for Cleared Swaps,
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