MFA Comment Letters

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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 to ESMA on its Technical Advice to the European Commission for Implementing AIFMD09.23.11


MFA submitted comments to ESMA on its consultation on Third Country Provisions in the AIFMD. In our response, among other […]

Comment Letter to ESMA on its Draft Technical Advice to the European Commission for Implementing AIFMD09.13.11


MFA submitted comments to ESMA on its consultation on possible implementing measures of the Alternative Investment Fund Managers Directive (AIFMD). […]

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Topics: AIFMD the directive, Level 2, third party managers, European Commission, consultation paper, AIF, UCITS Directive, MiFID, professional investors, retail investors, marketing, counterparties, prime brokers, net asset value, Article 61, AUM, AUM Calculations, mark-to-market, EU investors, sub-investment managers, Dodd-Frank, U.S. Securities and Exchange Commission, SEC, Investment Advisers Act of 1940, Advisers Act, registration, private funds, G-20, international coordination, Article 3(2), Article 9(3), professional indemnity insurance requirements, Gross Method, exposure, leverage, foreign exchange hedging position, interest rate hedging position, Box 93, Box 2, Box 1, NAV, Advanced Method, Box 13, diligence requirement, OTC transaction, securities lending agreement, repurchase agreement, Box 19, Box 29, risk management, risk limits, operational risk, portfolio management, market risk, portfolio risk, liquidity risk, gates, side pockets, redemption policy, depositaries, depositary, bespoke system, Box 78, collateral directive, Box 79, liability standards, Financial Services Authority, FSA, re-hypothecation provisions, Box 81, Box 86, due diligence, sub-custodian, Box 88, segregation, Box 89, omnibus accounts, liability regime, Box 95, Box 99, Value at Risk, VaR, Commitment Method, European Central Bank, ECB, Committee on European Securities Regulators, CESR Guidelines, credit default swap, CDS, remuneration, EU Passport, transparency, Box 106, passport regime, safe-keeping function, confidentiality, proprietary information, systemic risk, semi-annual reporting, collateral, counterparty exposures, Form PF, reporting period, generally accepted accounting principles (GAAP), Level 2 inputs, Level 3 inputs, valuation agents, underwriters, unobservable,