MFA Comment Letters

Related Legislation: CEA

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 […]

Comment Letter to SEC and CFTC on Proposed Rules Defining ‘Swap,’ ‘Security-Based Swap,’ and ‘Security-Based Swap Agreement,’ and Guidance on Mixed Swaps and Security-Based Swap Agreement Recordkeeping07.22.11


MFA submitted comments to the SEC and CFTC in response to their request for comments on their proposal on the […]

Click to expand relevant topics

Topics: 1993 energy exemption alternative delivery procedures, alternative transfer structure, antifraud liabilities, assignment and assumption agreements, bankruptcy estate, beneficial ownership interest, book-out contracts, business conduct requirements, capital, central clearing, CFTC, commodities, Commodity Futures Trading Commission, current debtor-creditor relationship, deferred shipment, delivery, direct or indirect ownership, eligible contract participants, energy commodities, exchange trading, Federal Securities Laws, forward contract exclusion, further definitions of swap, grantor, institutional investors, lender of record, liquidity, LMA, loan agreement, loan arrangers, loan market association, loan markets, loan participants, loan participations, loan payments, Loan Syndications and Trading Association, loan total return swaps, loan transfer mechanism, LSTA, margin, market participants, material non-public information, mixed swaps, netting, non-U.S. counterparties, nonfinancial commodity, oil, OTC derivatives, participant, participation agreements, physical commodity, physically settled, primary loan markets, private market, recordkeeping, reference loan, reporting, SEC, secondary loan markets, Securities and Exchange Commission, security, Security-Based Swap, security-based swap agreement, security-based swap agreement recordkeeping, syndicated loan market, synthetic exposure, systemic risk, total return payer, total return receiver, true participants, true participation, true sale, U.S. domiciled counterparties,

Comment Letter to the CFTC on its Proposed Rules on Risk Management Requirements for Derivatives Clearing Organizations03.21.11


MFA submitted a comment letter to the CFTC on its proposed rules on Risk Management Requirements for Derivatives Clearing Organizations. […]

Click to expand relevant topics

Topics: $50 million upper limit antitrust considerations, Bank of America-Merrill Lynch, bilateral trades, capital requirements, CFTC, Chicago Board of Trade, cleared trade volumes, clearing member, clearinghouses, Columbia University, committee on payment and settlement systems and technical committee of the International Organization of Securities Commissions, Commodity Futures Trading Commission, competition, connectivity, counterparty credit assessment practices, CPSS-IOSCO standards, credit risk, creditworthiness, cross product margin, customer initial margin, DCM, DCO, DCO concentration risk, DCO margin methodologies, default management framework, derivatives clearing organizations, Designated Contract Market, differentiated margining, direct clearing members, direct clearing members' initial margin, diversity of market participants, effective date, electronic execution, eligibility standards, excess margin, executing counterparty, fair and open access, federal register, Federal Reserve Bank of New York, five-day liquidation horizon, futures, global banking crisis, greater market concentration, guaranty fund scaling methodologies, hedge fund industry, highly liquid instruments, initial margin, initial margin requirements, investment banks, ISDA, leverage ratio, mandatory central clearing, margin, margin calculation utility, margin calls, margin methodology, margin requirements, mark-to-market variations, market liquidity, market volatility, minimum capital requirements, net capital obligation, non-hedge positions, obligations, on-the-run 10 year interest rate swaps, participant eligibility, phase-in period, portfolio margining, product eligibility, product portfolio, risk exposure, risk management, Risk Management Requirements, risk-based methodologies, scaling requirements, SEC, Securities and Exchange Commission, SEF, standard two-way protocols, stress and default scenarios, Swap Execution Facility, swap portfolio, swap portfolio size, swaps, systemic risk mitigation, The Turner Review, threshold guaranty fund contribution, tiers, transaction volume, volatility,

Comment Letter to the CFTC on its Proposed Core Principles and Other Requirements for Swap Execution Facilities03.08.11


MFA submitted a comment letter to the CFTC on its proposed Core Principles and Other Requirements for Swap Execution Facilities. […]

Click to expand relevant topics

Topics: annual review auction-based methods, available for trading, bilateral trading, bilateral trading environment, block size, block trade thresholds, block trades, cash position, CBOE futures exchange, CEA, central limit order variants, CFTC, chief compliance officer, cleared swaps, Commodity Futures Trading Commission, competition, complete audit trail, conflicts of interest, congestion, connectivity, credit default swaps, crossing, daily trading records requirements, data analysis, DCM, dealer-to-customer platforms, debt instrument, Designated Contract Market, discreet contract, electronic platform, emergency procedure, exchanges, exchanges for physical, exchanges for swaps, execution protocol, fixing, flexibility, futures position, grace period, grandfather relief, institutional investors, interstate commerce, ISDA, joint the trade, large notional transaction size threshold, limit order, linked transactions, liquidity, liquidity characteristics, major swap participants, Mandatory Execution Requirement, mandatory minimum required recipients, mandatory objective criteria, mandatory transparent criteria, Manipulation, market efficiencies, market liquidity, market-based competition, matching, matching traders, minimum block sizes, minimum block threshold, multiple-to-multiple trading venues, non-continuous liquidity, off-market transactions, one-to-one voice services, open outcry trading pits, order book, order book systems, OTC, OTC market, Over-the-Counter, Over-the-Counter Derivatives Markets, packaged transactions, permitted transactions, physical contract, physical position, price distortion, public information, quote requesters, quote-requesting participant, real-time public reporting of swap transaction data, recordkeeping requirements, regulatory efficiencies, reporting requirements, request for quote, required transactions, responsive quote, resting bids, RFQ, RFQ response period, RFQ system, Rulebook, SB SEF, security-based swap execution facility, SEF trading platforms, SEFs, SIFMA, single joint transactions, sporadic liquidity, swap data repositories, swap execution, swap execution facilities, timing delay, trading venues, transparency, voice-based system, voice-based trading, widened bid/offer spreads,

Comment Letter to the CFTC on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants02.28.11


MFA submitted a comment letter to the CFTC on its proposal on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for […]

Click to expand relevant topics

Topics: banks best practices, bid spreads, bilateral portfolio compression exercise, bilateral portfolio reconciliation exercise, broader markets, calendar day, CFTC, clearance, clearing satisfying requirements, collateral management, collateral steering committee of the International Swaps and Derivatives Association Inc., Commodity Futures Trading Commission, complex swap, compliance period, confirmation, confirmation periods, confirmation requirement, consistent timing, Counterparty, counterparty risk, customized swaps, DCM, DCO, derivatives clearing organization, Designated Contract Market, dividend payment, dollar threshold, electronic matching platforms, electronic matching process, electronic processing, exchange execution, financial entities, financial entity, heavily negotiated swaps, hedging risk, insurance companies, ISDA, legal risks, life cycle events, limiting parties, liquidity, major swap participants, mandated timeframes, margin disputes, market disruption, market participants, market risk, market-driven solution, merger, modification, MSPs, multilateral compression, multilateral portfolio compression exercises, multilateral portfolio reconciliation exercise, nominal value, novation, offer spreads, operational abilities, operational risk, over-the-counter derivatives, partial termination, pension plans, portfolio compression requirements, portfolio compression rule, portfolio reconciliation, position level discrepancies, position level portfolio reconciliation, post-trade exercises, pre-trade draft acknowledgement requirement, private funds, rights, risk mitigation benefits, SDs, SEC, Securities and Exchange Commission, SEF, swap dealers, Swap Execution Facility, swap markets, swap portfolio trade confirmation, swaps portfolio, time-sensitive swaps, timing requirements, trade acknowledgment, trade capture system, trade execution, valuation data, valuation discrepancy, Valuation Disputes, volatility,

Comment Letter to the SEC on Establishment of a Registration Regime for Municipal Advisors as Required by the Dodd-Frank Act.02.22.11


MFA submitted a comment letter to the SEC in response to its proposal to establish a registration regime for municipal […]

Click to expand relevant topics

Topics: ABN AMRO Bank N.V. affiliate letters, ancillary services, bank deposits, CFTC regulation, commodity for future delivery, commodity trading advisors, common control, CTAs, dually-registered investment advisers, duplicative registration, exempt reporting advisers, foreign private advisers, Form ADV, Form MA, guaranteed investment contracts, investment advisers, investment advisory services, investment strategies, Kleinwort Benson Investment Management Limited, mid-sized adviser, multi-jurisdictional advisory firms, municipal advisor, municipal advisors, municipal advisory activities, municipal derivatives, municipal escrow investments, municipal financial products, municipal securities, Murray Johnstone Holdings Limited, no-action letters, option, participating affiliate agreements, pay to play rule, pooled investment vehicle, pooled investment vehicles, pools of assets, primary investors, private adviser exemption, private fund advisors, private fund managers, registered advisor, registered broker-dealer, registered CTAs, registered investment advisers, regular oversight, regulated persons, Royal Bank of Canada, SEC, SEC No-Action Letter, SEC oversight, SEC regulation, SEC resources, SEC-registered entities, Securities and Exchange Commission, securities futures product, Security-Based Swap, self-regulatory entity, solicitation, state entity, state securities commission, state-registered investment advisors, third-party solicitor, transition period for registration, Uniao de Banco de Brasileiros, venture capital funds,

Comment Letter to the SEC and CFTC on Definitions of “Swap Dealer, Security-Based Swap Dealer (together, SDs), Major Swap Participant, Major Security-Based Swap Participant (together MSPs) and Eligible Contract Participant (ECP)02.22.11


MFA submitted a comment letter to the SEC and CFTC on their joint proposed rule to further define swap dealer, […]

Click to expand relevant topics

Topics: abnormal price movement acknowledgment requirements, applicable MSP thresholds, asset mix, bank capital standards, capital markets, cash settled swaptions, CDS, CDS protection, central clearing, centrally cleared positions, CFTC, Chicago mercantile exchange, clearing member defaults, clearinghouse, CME, commercial hedging, commercial loans, Commodity Futures Trading Commission, counterparty domicile, counterparty exposure, credit default swaps, credit ratings, credit spreads, creditworthiness, currency based institutions, current uncollateralized outward exposure test, daily mark requirements, daily variation margin calls, daily volatility, Dealer, dealers, default risk, delta weighting, deregistration period, discount factor, ECP, eligible contract participant, end-users, feeder fund, financial counterparty, Financial Industry Regulatory Authority Inc., Financial Stability Oversight Council, FINRA, fixed downside risk, Form PF, Form PQR, FSOC, fund domicile, future exposure discount, hedge fund managers, hedge funds, high yield credit swaps, high-grade corporate securities, highly leveraged, highly liquid assets, independent amount of collateral, independent variable, index CDS, index derivatives, index reference entity, inflation, initial margin, interest rate swap, investment grade, investment-grade credit swaps, ISDA master agreements, jump-to-default risk, know your counterparty requirements, large private fund, liabilities to equity, LIBOR, limited purpose designations, liquidity, liquidity rights, longer-term leverage, Major Security-Based Swap Participant, Major Swap Participant, manager domicile, margin methodologies, mark-to-market exposure, market activity, market growth, market location, market-standard discount rate, master-feeder fund, minimum duration of status, mitigating commercial risk, msp, MSP definitions, MSP determination, MSP test, MSP thresholds, multiplier, non-ECP, non-investment grade, non-U.S. market, non-U.S. regulators., non-US domiciled fund, non-US entities, non-US securities, offshore fund, option expiration date, options on a swap, over-collateralization, overnight borrowing, physically settled swaptions, portfolio risk, potential future exposure calculation, potential future exposure test, potential systemic risk impact, Proposed Form PF section 1b, proposed form PF section 2(a), proposed form PF section 3, proposed form PF section 4, proposed Form PQR, quarters, question 11, question 27, question 38, question 47, question 5, question 68, reevaluation period, reference entity domicile, reproducible test, retail cash, Retail Forex Pool, risk factor multiplier, risk factor multipliers, risk mutualization, risk-mitigating tools, schedule B, SD, SD obligations, SEC, secured debt, Securities Exchange Commission, Security-Based Swap Dealer, security-based swaps, Senator Hagan, Senator Lincoln, short-term financing, short-term leverage, single-name CDS, smaller private fund, spread bank designation, substantial counterparty exposure, substantial position, swap rate, swap underlier, Swaps dealer, swaptions, systemic risk, systemically important, systemically important financial institution, term borrowings, threshold levels, tools of credit protection, trade verification, trading entity, traditional commodity pool, U.S. banking system, uncollateralized exposure, underlying instrument, undiversified market participant, United States financial markets, unpaid premiums, unsecured debt, upward adjustment, US entities, US Treasuries, valuation of collateral, variation margin, volatility,
Results 1 - 10 of 24