MFA Comments to the “Over-the-Counter Derivatives Markets Act of 2009”

November 09, 2009

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Topics: Department of the Treasury Obama Administration, regulatory framework, over-the-counter derivatives, OTC derivatives, institutional investors, commodity, securities market, OTC derivatives market, derivatives transactions, central clearinghouse, segregation, initial margin, variation margin, trade and position reporting, swap dealers, securities dealers, Major Swap Participant, AIG, end-users, substantial net position, substantial unsecured net position, AAA credit rating, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, CFTC, security-based swaps, dealers, credit risk, insurance companies, energy companies, airline, utilities, private funds, local governmental entities, non-dealer entities, capital restrictions, swap market participant, Long Term Capital Management, Enron Corporation, thrift and insurance holding company, American International Group, unsecured current credit exposure, central clearing, derivatives clearing organizations, proprietary assets, legacy standardized swaps, non-clearable trade, Gary Gensler, Lehman Brothers, LBIE, collateral segregation, bankruptcy-remote, Bankruptcy Code, risk management, Pension Funds, endowments, hedge funds, custodian, ISDA product definitions, registered derivatives clearing organization, non-cleared swap transactions, exchange trading, hybrid market, exchange-traded products, market manipulation, position limits, physically-delivered commodities, cash-settled contracts, pre-merger notification regime, capital formation,
From: MFA, Richard Baker

To:

Neal S. Wolin, Department of the Treasury

MFA submitted a letter to the Department of the Treasury regarding the Obama administration’s legislative proposal titled the “Over-the-Counter Derivatives Markets Act of 2009″ (“DMA”). A copy of the proposal can be found here. In our letter, MFA provided a number of comments, which we believe are consistent with the proposal’s public policy goals and will further enhance the benefits of OTC derivatives regulation.

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