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, SIFMA and GFXD Submit Joint Letter to the CFTC with Proposed Safe Harbor for the ECP Definition01.19.12


On January 19, MFA, SIFMA, and GFXD submitted a joint letter to the CFTC with a proposed safe harbor from […]

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

MFA Submits Comment Letter to CFTC on Proposed Dodd-Frank Implementation Rules for Mandatory Swap Clearing, Trade Execution, and Margin Rules11.04.11


The OTC derivatives reforms (Title VII) resulting from the Dodd-Frank Act will cause sweeping transformation of the OTC derivatives markets […]

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Topics: Commodity Futures Trading Commission CFTC, swaps, swap transaction, swap transaction compliance, clearing, trade execution, margining, margining requirements, Dodd-Frank Act, mandatory clearing, Rulemaking, Gary Gensler, central clearing, market participants, buy-side participants, end-user exemptions, product definition rules, Securities and Exchange Commission, SEC, security-based swaps, swap dealer, Security-Based Swap Dealer, Major Swap Participant, Major Security-Based Swap Participant, collateral, full-scale clearing, uncleared swaps, liquidity, execution, Category 2 Entities, Category 1 Entities, active fund, buy-side market participants, private funds, swap execution facilities, SEF, Designated Contracts Markets, DCMs, real-time reporting, swap data, Regulators, derivatives clearing organization, futures commission merchants, FCM, non-dealer market participants, clearing mandate, G20, OTC derivatives, over-the-counter derivatives, exchanges, electronic platform, central counterparties, CCP, federal register, class of swaps, voluntary clearing, Category 3 Entities, Scott O'Malia, compliance schedules, compliance date, made available for trading, partial tear-ups, novations, third-party subaccount, non-MSP counterparties, interest rate swaps, broad-based index credit default swaps, commodity swaps, systemic risk, real-time clearing, cost-benefit analysis, price distortion, bilateral execution, execution venue, listing, security-based swap SEF, Category 4 Entities, trading documentation, phased implementation, transparency, prudential regulators, variation margin, netting, counterparties,

Comment Letter on IOSCO’s Consultation Report on ‘Regulatory Issues Raised by the Impact of Technological Changes on Market Integrity and Efficiency,’08.12.11


MFA submitted comments to IOSCO on its consultation report on Regulatory Issues Raised by the Impact of Technological Changes on […]

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Topics: Mr. Werner Bijkerk International Organization of Securities Commissions, Spain, Technical Committee of the International Organization of Securities Commissions, OSCO, Regulatory Issues Raised by the Impact of Technological Change on Market Integrity and Efficiency, Consultation Report, high frequency trading, HFT, market trends, technological developments, institutional investors, pensions, endowments, foundations, insurance companies, market liquidity, Economic Growth, market efficiencies, market access, market information, transaction fees, order execution, Technical Committee, empirical data, algorithmic trading, trading strategies, Gomber, Arndt, Lutat, Uhle, transaction delivery, Peter Gomber, electronic markets, computer programs, monopolies, proprietary, investment time horizons, low latency, broker dealers, sponsored access, spreads, fees, execution speed, market depth, efficiency, transparency, pricing reliability, TAGG Group, fixed commission rates, Schwab, E-Trade, Fidelity, TD Ameritrade, passive, long-term, mutual funds, algorithms, proprietary trading tools, executing brokers, third party vendors, buy-side brokers, fiduciary obligation, educational campaigns, Flash Crash of May 6, 2010, flash crash, market dislocations, Dow Jones Industrial Average, Market Break of 1962, Securities Exchange Commission, SEC, 1963 Special Study of the Securities Markets, 1963 Special Study, New York Stock Exchange, dark pools, wait-and-see, single-stock circuit breakers, CFTC, Joint Advisory Committee on Emerging Regulatory Issues, bid-ask spreads, Thomson, NBBO, Barclays Capital Equity Research, EU, Japan, Germany, UK, France, Nasdaq, Merrill Lynch, Goldman Sachs, LaBranche, Barclays Plc., institutional investor, Financial Crisis of 2008, Rosenblatt Securities, AIG, Fannie Mae, Freddie Mac, Washington Mutual, Market Crash of 1987, intermediary firm, DEA, circuit breakers, limit-up/limit-down systems, erroneous trades, Elizabeth Murphy, Joint Industry Limit Up-Limit Down Proposal, two-sided displayed quotes, oversight, affirmative stock locate framework, ETFs, quote stuffing, order-to-trade ratios, co-location services, standardize disclosure, connectivity, TABB Group, effective spreads in European equities, Division of Risk, Strategy and Innovation memorandum, threshold securities, National Securities Clearing Corporation, NSCC, Office of Markets in the Division of Risk, Strategy and Financial Innovation,