MFA Comment Letters

Topic: UK Financial Services Authority

MFA Submits Comments to ESMA on Short Selling and Sovereign CDS03.09.12


MFA submitted comments in response to ESMAs public consultation on possible delegated acts concerning the Regulation on short selling and […]

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Topics: European Securities and Markets Authority ESMA, Regulation on short selling and certain aspects of credit default swaps, uncovered short sales and credit default swaps, Level 2 process, natural or legal person, short sale, civil law, securities law, sovereign issuer, EU Member State, net short positions, sovereign debt, long positions, convertible bond positions, France, Spain, Italy, Belgium, issued share capital, convertible debt securities, holding a share, financial instrument, short selling bans, quantitative threshold for high correlation, market participants, buffer periods, interest rates, Instituto de Credito Oficial, ICO, Ministry of Economy and Finance, Secretariat of State for the Economy, Financial Agency of Spain, liquid market price, maturity bucket, delta adjusted method, notional basis, convertible debt, broad-based indices, Eurostoxx, narrow-based indices/baskets, sector-specific, underlying shares, disaggregation, financial institutions, UK Financial Services Authority, FSA, anti-avoidance provision, publicly available information, debt instruments, Alternative Investment Fund Managers Directive, AIFMD, credit quality, yield curve, sensitivity adjusted method, ETF, fund management activities, aggregation of positions, netting, pan-European short selling disclosure regime, CESR, delegate, group, consolidated accounts, credit default swap, default risk, uncovered credit default swap, sovereign CDS, hedged portfolios, asset managers, correlation test, intra-Member State correlation, subordinated debt, trust preferred securities, RBS, BNP Paribas, Societe Generale, interest rate swap, IRS, bank name CDS, emergent systemic risk, Greece, Ireland, Austria, Portugal, IRS curve, Italian CDS, sovereign bonds, credit protection, anticipated correlation, tail risk hedging, tail risk, severe market turmoil, reference asset, contract of insurance, Leonard Ng, Buttersworth Journal of International Banking and Financial Law, insurable interest, indices, supra-national European body, Markit iTraxx SovX Western Europe Index, proprietary models, listed securities, CDS transaction, eurozone, Italian lira, redenomination, uncovered position, static or dynamic hedging strategy, indirect exposures, threshold of liquidity, OTC instruments, legitimate market operations, illiquid shares, corporate bonds, money market instruments, UCITS, short selling, margin level, clearing house, option, future, swap, forward rate agreement, derivative instrument, central clearing, Italian CONSOB, convertible bonds, Member State regulator, sovereign CDS transactions,

Comment Letter to ESMA on Short Selling and Credit Default Swap Regulation01.10.12


MFA submitted a comment letter on January 10 to the European Securities and Markets Authority (ESMA) regarding the implementation of […]

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

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Topics: private funds commodity pool operators, commodity trading advisors, Form PF, systemic risk, Financial Stability Oversight Council, market participants, managed futures, absolute return strategies, SEC, CFTC, Dodd-Frank Act, Council and Office of Financial Research, OFR, global regulators, overcounting, undercounting, threshold for enhanced performance, assets under management, reporting period, confidentiality protections, inadvertent disclosure, non-bank financial companies, lending institutions, interconnectedness, liquidity risk, maturity mismatch, regulatory scrutiny, systemically significant, Federal Reserve System, the Fed, Form CPO, Form PQR, Form CTA-PR, targeted requests, tiered reporting system, threshold, trading and investment strategies, borrowing arrangements, collateral practices, operational capabilities, illiquid assets, investment advisers, bespoke contracts, private equity, privately issued convertible bonds, equity derivatives, distressed debt, unaffiliated third party sources, generally accepted accounting principles, GAAP, Level 2 inputs, Level 3 inputs, Financial Accounting Standards Board, audited financial statements, UK Financial Services Authority, FSA, Form 13F, public companies, Form 10-K, Form 10-Q, portfolio management, CUSIP number, semi-annual reporting, counterparty exposures, market noise, short-term market fluctuations, margin requirements, hedge fund defaults, large private fund manager, qualifying fund, hedge fund assets under management, Form ADV, proposed reporting thresholds, interpretive guidance, private fund managers, recordkeeping requirements, section 404, confidentiality of information, proprietary information, Investment Adviser Registration Depository, Schedule 13G, individual certification, valuation methodology, proprietary methodology, alternative methodology, de minimis, master-feeder, parallel funds, equity prices, interest rates, currency rates, Form PF question 36, form PF questions 28 and 35, funds of funds, direct investments, aggregate gross asset value, collateral, operational efficiency, ten-year option, five-year option, master agreement, regulatory assets under management, net assets under management, leverage, parallel managed accounts, net asset value, gross asset value, creditor, net borrowings, aggregate borrowings, beneficial owners, record owners, fixed advisory fees, investment expenses, performance fees, inception class, statistical arbitrage-equity, other quantitative strategies, strategy exposure, risk capital allocation, NAV, futures commission merchants, FCMs, direct clearing members, DCMs, prime brokers, clause (iii), loan commitments, offsetting exposure, tri-party collateral accounts, market value, asset-backed securities, debt securities, swap contracts, futures contracts, foreign currency contracts, notional value of derivatives, notional amount, long positions, short positions, LMV, SMV, maturity brackets, short-term interest rate, DV01, CR01, duration, non-rated issues, short term high quality corporate debt, foreign exchange derivatives, turnover rate, GMV, Bloomberg, risk methodology, repos, sensitivity analyses, liquidity management, balance sheet value, delta adjusted, variation margin, equity exposure, rehypothecated initial margin, CCPs, central clearing counterparties, Value at Risk, VaR, CDS, CDX, default rates, corporate bonds, short borrowing, synthetic borrowing, uncommitted lines of credit, side pocket arrangement,

MFA Response to CESR Consultation Paper on a Proposal for a Pan-European Short Selling Disclosure Regime10.01.09


MFA submitted a letter to the Committee of European Securities Regulators (CESR) today in response to its Consultation Paper on a […]

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Topics: Committee of European Securities Regulators CESR, CESR Proposal for a Pan-European Short Selling Disclosure Regime, alternative investment managers, hedge funds, fund of funds, hybrid funds, 130/30 funds, managed futures funds, industry service providers, alternative investment industry, absolute return strategies, short selling, manipulative conduct, Market Confidence, stability, public disclosure of short positions, short positions, market volatility, price discovery, risk management, risk management function, significant adverse effect, financial services sector, investors, Issuer, market participants, de minimis, aggregated anonymised data, timeframe for reporting, transparency directive, meaningful data, short selling bans, global equity markets, academics, liquidity, bid-ask spread, price declines, materially negative impacts, market efficiency, short selling disclosure regime, equity markets, enhanced transparency, investment managers, abusive short selling practices, abusive practices, financial institutions, herding, institutional investors, retail investors, transaction costs, capital markets, free flow of information, chilling effect, alternative investment classes, Pension Funds, endowments, foundations, alternative investment vehicles, hedging strategies, capital formation, hedge, convertible arbitrage, short equity position, convertible bonds, traditional bond issuance, convertible securities, short squeeze, Reverse Engineered, trading strategies, long equity positions, exposures, Unwind, financial stocks, pricing efficiency, short selling prohibitions, European markets, large-scale short selling, extreme market conditions, negative returns, UK Financial Services Authority, FSA, securities prices, naked short selling, Journal of Finance, Credit Suisse, market stability, disclosure thresholds, private reporting, flagging short sales, Financial Regulatory Authority, FINRA, flagging regime, disproportionate costs, real time information, over-the-counter transactions, exchanges, trading platform, settlement, physical short sales transactions, EEA stock, extraterritoriality, European Union, EU, EEA equities, two-tier disclosure model, price amplification, market testing, MiFID, competent authorities, Member State competent authorities, professional secrecy, confidentiality, freedom of information regimes, harmonization, net economic short positions, transitory short position, abusive behavior, share issues, capital raising, index trading, basket trade, reporting regimes, net economic short position, asset management company, aggregation, prudential regulators, T+1 reporting, derivatives, derivative positions, delta adjusted, cumulative compliance costs, global capital markets, EU Member State, market maker, market making,
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