MFA Comment Letters

Please contact Scott McDonald with any questions or technical difficulties. You can email your request to smcdonald@managedfunds.org or call 202-730-2600. MFA is continuously updating the database, so check back often when searching for comment letters.

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MFA and AIMA Submit Joint Letter to CFTC on Further Proposed Cross-Border Guidance02.06.13


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

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Topics: Commodity Futures Trading Commission CFTC, Cross-Border, swaps, duplicative regulation, Alternative Investment Management Association, AIMA, Dodd-Frank Act, prime brokers, hedge fund managers, U.S. person, interpretive guidance, market participants, Corporation, partnership, Limited Liability Company, LLC, Trust, joint-stock company, direct or indirect ownership, commodity pool, pooled accounts, collective investment vehicles, commodity pool operator, CPO, pension, estate, income tax, principal place of business test, investment manager, limited liability partnership, LLP, investment fund, ownership test, derivatives, OTC derivatives, over-the-counter derivatives, OTC derivatives market, international harmonization of regulations, regulatory framework, swap dealer, Major Swap Participant, msp, Securities and Exchange Commission, SEC, European Securities and Markets Authority, ESMA, European Parliament, Council of the European Union, central counterparty, CCP, trade repositories, mandatory clearing requirements, clearing, central clearing, systemic risk, Gary Gensler, Mary Schapiro, OTC derivatives reform, CPPSS-IOSCO, IOSCO, International Organization of Securities Commissions, European Union, EU, Hong Kong Monetary Authority, Hong Kong, Monetary Authority of Singapore, Singapore, MAS, foreign regulators, Dealer, buy-side market participants, registration, adviser registration, Office of the Comptroller of the Currency, OCC, majority ownership, Look Through, fund of funds, listed entity, Form CPO-PQR, de minimis, commodities, phase-in period, execution, G20, G20 commitments, transparency,

MFA Submits Accompanying Portfolio Margining Letter11.26.12


MFA submitted a supplemental comment letter to the U.S. prudential regulators during the reopened comment period for their proposed rulemaking […]

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Topics: Office of the Comptroller of the Currency Federal Housing Finance Agency, Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation, FDIC, Farm Credit Administration, capital requirements, margin, covered swap entities, prudential regulators, swap dealer, Major Swap Participant, Security-Based Swap Dealer, Major Security-Based Swap Participant, Dodd-Frank Act, portfolio margining, cross-margining, futures, options, swaps, security-based swaps, Commodity Futures Trading Commission, CFTC, futures commission merchant, FCM, broker-dealer, initial margin, collateral, Securities and Exchange Commission, SEC, regulatory regime, market participants, Options Clearing Corporation, Chicago mercantile exchange, New York Portfolio Clearing LLC, LCH.Clearnet Ltd., capital markets, over-the-counter derivatives, OTC derivatives, master netting agreements, affiliate-held collateral, Dealer, derivatives clearing organization, segmentation, market liquidity, liquidity, end-users, hedging, mandatory clearing, credit default swap, CDS, index CDS, redundant margin, swaptions, caps, floors, cross-currency swaps, inflation swaps, Cleared Products, risk, CME Group, CME Clearport, ICE Clear Credit, ICE Clear Europe, central counterparties, CCP, buy-side, debt obligation, systemic risk, posted margin, Collecting Futures Commission Merchant, Depositing Futures Commission Merchant, triangular setoff, uncleared swaps, bankruptcy, commodity broker, In re Lehman Brothers Holdings Inc et al, Chevron Products Co. v. SemCrude L.P., covered swap entity, eligible collateral, Federal National Mortgage Association, Federal Home Loan Mortgage Corporation, Federal Home Loan Banks, Federal Agricultural Mortgage Corporation, insured obligation, Farm Credit System,