MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners

July 30, 2014

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Topics: CFTC Commodity Futures Trading Commission, Timothy Massad, Mark Wetjen, Scott O'Malia, Sharon Bowen, J. Christopher Giancarlo, swaps, commodity pool operators, CPO, commodity trading advisors, CTA, alternative investment strategies, Dodd-Frank Act, OTC derivatives, systemic risk, transparency, central clearing, swap execution facilities, SEF, designated contract markets, DCM, regulation, package transactions, market infrastructures, recordkeeping requirements, swap data reporting, Cross-Border, central counterparties, CCP, third country, regulatory requirements, alternative investment funds, EMIR, JOBS Act, private investment vehicles, regulatory framework, hedge fund, fund of funds, private equity fund, real estate investment trust, burdensome, CPO delegation, temporary interim relief, private funds, harmonization, no-action relief, SEC, Securities and Exchange Commission, Policy Makers, customer protection, U.S. Congress, Bankruptcy Code, futures commission merchant, FCM, legal segregation with operation commingling, LSOC, market participant, MF Global Inc., Peregrine Financial Group, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, segregated account, FCM counterparty, position limits, buy-side, straight-through processing, made available for trading, MAT, inter-dealer market, anonymity, execution, proprietary trading tools, dealer-to-customer platforms, liquidity, derivatives clearing organization, DCO, Dealer, interest rate markets, swap curves, swap butterflies, invoice spreads, swaptions, Vincent A. McGonagle, exchange for related position, EFRPs, benchmark contracts, SIFMA AMG, Asset Management Group of the Securities Industry and Financial Markets Association, Division of Swap Dealer and Intermediary Oversight, Division of Market Oversight, introducing broker, assets under management, AUM, trading privileges, commodity pool, floor brokers, Alternative Investment Management Association, AIMA, swap data repository, SDR, Commodity Markets Council, alpha swap, beta swap, gamma swap, Major Swap Participant, MSPs, European Union, EU, bespoke swaps, International Swaps and Derivatives Association, ISDA, master agreement, European Commission, OTC Derivatives Regulators Group, mandatory clearing, United States, Cayman Islands, U.S. person, swap dealer, financial counterparty, commodity interests, privately offered commodity pools, Cayman Islands Monetary Authority, British Virgin Islands Financial Services Commission, Financial Conduct Authority, Hong Kong, Securities and Futures Commission, private investment funds, limited partnership, general partner, corporations, Trust, limited liability companies, public investment fund, board of directors, chilling effect, NFA, National Futures Association, due diligence, compliance, registered investment adviser, President Obama, Obama Administration, U.S. Department of the Treasury, quarterly account statements, service providers, illiquid assets, Form PF, Form CPO-PQR, Form CTA-PR, custody rules, generally accepted accounting principles, GAAP, Form PQR, haircuts, Committee of Payment and Settlement Systems, International Organization of Securities Commissions, IOSCO, Financial Stability Board, FSB, risk management, initial margin, variation margin, loss allocation, Full Physical Segregation, customer collateral, collateral, insolvency, cleared swaps, hedgers, short, price discovery, spot-month position limits, physically settled, cash-settled contracts, natural gas, gold, silver, owned entities, passive ownership, exemptive relief, speculation, aggregation,
From: MFA, Stuart Kaswell

To:

Timothy Massad, CFTC
Mark Wetjen, Scott O'Malia, Sharon Bowen, J. Christopher Giancarlo, CFTC

MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the other four Commissioners, Mark Wetjen, Scott O’Malia, Sharon Bowen, and J. Christopher Giancarlo.  (Appendices A-H for each letter)  The letters spelled out MFA’s current priorities with the CFTC, reiterating points raised in earlier letters and in testimony before Congress.

MFA raised a number of the industry’s most pressing issues in the letter to Chairman Massad and the Commissioners.  A number of the issues we addressed include:

  • Impartial Access to SEFs and SEF Implementation Concerns.
  • Exemption for SEF Members that are Registered CTAs/CPOs from Rule 1.35(a)’s Oral and Written Recordkeeping Requirements.
  • Swap Data Reporting Issues.
  • Cross-Border Issues.
  • Delegation of CPO Obligations.
  • CPO/CTA Recordkeeping Requirements.
  • CFTC/SEC Harmonization Issues, including JOBS Act.
  • Protection of Customer Collateral Issues.
  • Rulemaking Proposals on Position Limits.

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