MFA Comment Letters

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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 […]

Supplementary Letter to the SEC in Response to its Proposed Antifraud Rule with Respect to Security-Based Swaps03.29.11


MFA submitted a letter to supplement our December 23, 2010 letter to the SEC in response to its proposed antifraud […]

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Topics: Securities and Exchange Commission SEC, Fraud, Manipulation, Deception, security-based swaps, anti-fraud rule, security based swaps market, cost-benefit analysis, honest markets, legitimate market activity, US OTC derivatives market, derivatives market, swaps market, legitimate market participation, purchase, sale, definitions, statutory authorization, security based swap anti-fraud rule, Securities Industry and Financial Markets Association, International Swaps and Derivatives Association Inc, The Loan Syndications and Trading Association, maturity date, context, bilateral contracts, novations, unwinds, assignments, execution, termination, assignment, exchange, transfer of rights/obligations, conveyance of rights/obligations, extinguishment of rights/obligations, total return swaps, credit default swaps, transferor, credit events, corporate actions, underlying shares, disruption events, termination events, collateral, systemic risk, interim payments, premium payments, spread payments, material non-public information, ISDA master agreement, clearing agreement, counterparty defaults, bankruptcy proceedings, Bankruptcy Code, automatic stay provisions, price discovery process, fair dealing, competition, capital formation, Financial Crisis Inquiry Commission, single name credit default swaps, non-index multi-name credit default swaps, equity linked forwards, equity-linked swaps, unallocated swaps, Bank of International Settlements, BIS, price discovery, primary participant, secondary participant, credit exposure, equity exposure, institutional leveraged loans, investment grade bonds, Financial Stability Board, primary debt issuance, investment grade loans, leveraged loans, LBO-related loans, corporate loans, high yield bonds, Loan market Review, Reuters, SEC v. Rotech, FCIC, CDS market, swap market, financial crisis, price efficiency, investor confidence, material dislocation,

Comment Letter to the CFTC in Response to its Request for Comments on Position Limits for Derivatives03.28.11


MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains […]

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Topics: CFTC Commodity Futures Trading Commission, position limits, derivatives, futures, option contract, swap contract, futures market, price risk, commercial participants, operating company, financial institution, energy market infrastructure, liquid price discovery, risk-shifting market, market manipulation, federal limits, crowding out provision, spot month, disaggregation relief, deliverable supply, inter-commodity spread transactions, bona fide hedger, price discovery, risk management, commodity market, annual recalculation methodology, U.S. futures exchange, delivery point, individual class rules, legacy position limits, agricultural commodities, disorderly markets, spot-month position limits, referenced contracts, aggregate spot-month position limits, swaptions, DCMs, physically delivered contracts, cash-settled contracts, conditional-spot month limit, cash position, forward position, physical commodity deliverable, aggregate all-months-combined, aggregate single-month, futures class all-months-combined, futures class single-month, swaps class all-months-combined, swaps class single-month, open interest, non-spot position limits, calendar-spread exemption, hedging transaction, cash market transaction, cash market risk, swap dealer hedge exemption, pool participant, future commission merchants, FCMs, independently controlled and managed trader, account aggregation requirements, enumerated agricultural commodities, open interest formula, position visibility, reporting requirements, offsetting positions, excessive speculation, interstate commerce, physical commodity, interest rates, stock indices, squeezes, market liquidity, global commodity, regulatory oversight, risk transfer, energy price volatility, CTFC Inter-Agency Task Force on Commodity Markets, GAO, IOSCO, IMG, UK Treasury, CME, The Economist, supply and demand, U.S. dollar, price volatility, NYMEX crude oil price, speculative investment, crude oil futures, International Organization of Securities Commission, IOSCO Technical Committee, IMF World Economic outlook, HM Treasury Global Commodities, OECD publishing, JP Morgan, long positions, hedge funds, short positions, Chicago onions, Berlin wheat, Credit Agricole, Energy Risk, University of Calgary, PKVerleger LLC, Wall St. Journal, Artificial limits, Barclays Capital, OECD Food, Jacks Study, Commission Energy Complex Report, Global Energy Management Institute, Bauer College of Business, University of Houston, House Committee on Agriculture, Pirrong Testimony, price spikes, agricultural model, metal commodity, seasonal variation, market surveillance, OTC, WTI, independently controlled accounts, independent third party, commodity trading advisors, common parent, CPO, CTA, control standard, commodity pool operator, commodity trading advisor, eligible entity, order routing arrangement, disclosure documents, non-financial entity exemption, active trading program, passive trading program, funds of funds, private equity investments, passive investors, pension plan, independent account controller exemption, asset manager, corporate enterprises, speculative trading ventures, CFTC docket no. 11-05, CFTC docket no. 08-02, pool participant exemption, equity interest, market depth, no-action relief, percentage interest, real-time basis, university endowment, liquidity provisions, application based exemption, approval based exemption, annual renewal based exemption, self-executing disaggregation, reporting obligation, surveillance, audit, enforcement, cross-ownership of traders, statement of reporting trader, benchmark contracts, NYMEX Henery Hub Natural Gas contract, commercial hedgers, inter-commodity spread exemption, arbitrage exemption, directional position, outright positions, submarket, large trader data, seasonality, annual limits, CBOT, NYBOT, KCBOT, pre-existing position exemption, significant price discovery contracts, index fund manager, class limits, rounding, hypothetical portfolios, cleared bilateral contracts, non-cleared bilateral contracts, front month position, deferred month positions, last day swaps, penultimate swaps, options, delta, financial cal spread options, physical cal spread options, physical options, HH natural gas,

Comment Letter in Response to the FDICs Interim Final Rule Implementing Certain Provisions of the Orderly Liquidation Authority (OLA),03.28.11


MFA filed a comment letter in response to the FDICs interim final rule implementing certain provisions of the orderly liquidation […]

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Topics: Federal Deposit Insurance Corporation FDIC, Liquidation Authority provisions, orderly liquid authority, OLA, creditor losses, shareholder losses, liquidation process, systemically significant firm, non-statutory considerations, Bankruptcy Code, Federal Rules of Bankruptcy Procedure, financial market meltdown, covered financial institution, insolvency laws, insolvency proceeding, investor, systemic risk, transparency, estate, creditor participation, creditor involvement, market expertise, Disclosure, claim disallowance, judicial review, distress, volatility, moral hazard, market discipline, receivership, short-term creditors, debt instrument, allocation of capital, short-term financing, longer-term financing, bond holders, short-term lenders, providers of lines of credit, preferred creditors, equality of distribution, critical vendors, doctrine of necessity, Union Bank v. Wolas, chapter 7 liquidation, favored creditors, unsecured creditors, Board of Directors of FDIC, ratable payments, liquidation value, valuation of collateral, underlying collateral, unsecured claim, fair market value, US government securities, valuation rules, true market valuation, unsecured deficiency claim, quotes, market data, third-party market participants, valuation date, publicly traded securities, secured creditor, receivership estate, market fluctuations, swaps, repurchase agreements, securities contracts, bridge financial company, default, contingent claims, unduly delay, liquidation framework,

Letter to Mary Schapiro; Attachments: (Industry Letter on Buy Side Access to Clearing) and (Recommended Timeline for Adoption and Implementation of Final Rules Pursuant to Title VII of The Dodd-Frank Act)03.24.11


MFA submitted a letter to Chairmen Schapiro and Gensler, and each of the SEC and CFTC Commissioners, providing our recommendations […]

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Topics: Securities and Exchange Commission OTC derivatives market, reform, systemic risk, efficiency, global financial system, central clearing, liquid contracts, clearable contracts, trade repositories, cleared swaps, bilateral swaps, price transparency, liquid swap transactions, broad industry clearing, trade repository data, electronic data, trade transparency, buy-side participants, buy-side access, New York Fed, ISDA Governance Committee, IIGC, standardizing contracts, trade compression, OTC derivatives reform, milestones, phase-in period, sell-side firms, clearinghouses, Regulators, current clearable swaps, future clearable swaps, broad-based index credit default swaps, CDS, interest rate markets, single-name CDS, asset managers, end-users, CCPs, CMs, customer clearing services, open interest caps, waterfalls, block trading, risk compression, customer funds, pre-default portability, give-up agreements, US bankruptcy, non-US bankruptcy, cleared OTC derivatives, 14d order, 17f6 order, SEC exemptions, FINRA exemptions, margin methodology, CME rules, CME, ClearPort, migration, TBF, Bloomberg, MarkitWire, ICELink, end to end production testing, front-office processing, middle-office processing, back-office processing, back loading facility, end-to-end systems flow, fallback processing, post-default portability, risk waterfall process, net client omnibus margin account, price challenge protocol, financial disclosure requirements, clearing, commission fee, trading annex, give up process, transparency, default waterfall, futures, CDS books, margin segregation, Basel I capital requirements, FCMs, commodity contracts, Bankruptcy Code, roll-out schedule, margin regime, vendor, streamlined netting process, trade rejection rights, segregation framework, alternative margin segregation schemes, title transfer regime, English law CSAs, US banking regulators, US bank CM, non-US bankruptcy laws, non-US CM's default, position limits, real-time reporting, big bang approach, phase-in approach, derivatives clearing organizations, interest rate swaps, exchange trading, MSPs, hedge funds, dealer-to-dealer clearing, SEF trading, onboarding, mixed swap, swap dealer, eligible contract participant, DCO governance, DCO registration, collateral, Business Conduct Standards, capital requirements, margin requirements, MSP recordkeeping requirements, SD recordkeeping requirements, public reporting, liquidity, individual risk concentrations, block trade. swap initial margin, post-trade reporting, pre-trade reporting, interdealer reporting, Dodd-Frank clearing requirements, clearing agreement, execution agreement, clearing members, FIA, CFTC rules, SEC rules, mandatory clearing date, CCP implementation period, CCP risk management, end-user exemptions, Phase 1 mandatory cleared products, counterparty risk, OTC derivatives, standardized documentation, onboarding work streams, voluntary period, direct clearing participants, indirect clearing participants, voluntary targets, scale readiness, volume targets, simpler instruments, complex instruments, credit, voluntary back loading, compression, systemic counterparty risk, industry-level metrics, DTCC data, cleared settlement, uncleared settlement, tear-ups, long-only accounts, asset manager accounts, investor,

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,

Comment Letter to the CFTC on its Proposed Core Principles and Other Requirements for Swap Execution Facilities03.08.11


MFA submitted a comment letter to the CFTC on its proposed Core Principles and Other Requirements for Swap Execution Facilities. […]

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Topics: Commodity Futures Trading Commission CFTC, swap execution facilities, SEFs, SEF trading platforms, regulatory efficiencies, market efficiencies, market-based competition, transparency, real-time public reporting of swap transaction data, available for trading, competition, grandfather relief, request for quote, RFQ, order book, cleared swaps, block trades, timing delay, required transactions, Designated Contract Market, DCM, Mandatory Execution Requirement, annual review, market liquidity, minimum block threshold, large notional transaction size threshold, reporting requirements, recordkeeping requirements, daily trading records requirements, major swap participants, CEA, RFQ system, Over-the-Counter, OTC, electronic platform, one-to-one voice services, mandatory objective criteria, mandatory transparent criteria, OTC market, connectivity, grace period, liquidity, resting bids, swap data repositories, liquidity characteristics, bilateral trading environment, trading venues, dealer-to-customer platforms, exchanges, swap execution, bilateral trading, voice-based trading, flexibility, execution protocol, order book systems, multiple-to-multiple trading venues, limit order, central limit order variants, non-continuous liquidity, credit default swaps, responsive quote, interstate commerce, mandatory minimum required recipients, quote requesters, institutional investors, voice-based system, security-based swap execution facility, SB SEF, permitted transactions, block trade thresholds, block size, data analysis, minimum block sizes, joint the trade, auction-based methods, matching, fixing, open outcry trading pits, quote-requesting participant, widened bid/offer spreads, exchanges for physical, exchanges for swaps, off-market transactions, linked transactions, packaged transactions, single joint transactions, crossing, matching traders, futures position, physical position, cash position, debt instrument, physical contract, discreet contract, Manipulation, price distortion, congestion, sporadic liquidity, emergency procedure, public information, complete audit trail, conflicts of interest, chief compliance officer, ISDA, SIFMA, Over-the-Counter Derivatives Markets, CBOE futures exchange, RFQ response period, Rulebook,