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MFA Comment Letters

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Topic: automated trading

MFA Submits Comments on CFTC Concept Release on Risk Controls and System Safeguards for Automated Trading Environments12.11.13


MFA submitted comments to the CFTC regarding a concept release on risk controls and system safeguards for automated trading environments.  […]

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Topics: CFTC Commodity Futures Trading Commission, high frequency trading, automated trading, derivatives market, derivatives, automated trading system, trading software, HFT, transaction delivery, market disruptions, operational risk, infrastructure risk, security risk, clearing member, market participant, futures commission merchant, FCM, swap dealer, major swap participants, derivatives clearing organization, DCO, hedgers, hedging, liquidity, execution, market efficiencies, transaction costs, technology, designated contract markets, DCM, swap data repositories, swap execution facilities, SEF, trading platforms, commodity trading advisor, CTA, commodity pool operator, CPO, Securities and Exchange Committee, SEC, risk controls, limit up-limit down measure, self-regulatory organization, SRO, circuit breaker, CME Group, self-regulatory responsibilities, execution rate throttle, volatility, volatility awareness alert, Joint Advisory Committee on Emerging Regulatory Issues, contract market, self-match prevention, Broker, price collar, market volatility, futures market, Melissa Jurgens, NYSE Euronext, flash crash, direct market access order, Presidential Task Force on Market Mechanisms, price limits, Trading Pause, credit risk limits, FINRA, Financial Industry Regulatory Authority, kill-switch, trading platform, National Futures Association, NFA, proprietary information, FSOC, Financial Stability Oversight Council,

MFA Comments on FINRA Wash Sale Proposal09.25.13


Today, MFA filed a letter to the SEC on FINRA’s proposal to add supplementary material to FINRA Rule 5210 (Publication […]

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Topics: Securities and Exchange Commission SEC, FINRA, Financial Industry Regulatory Authority, wash sales, wash sale transaction, algorithms, algorithmic trading, inadvertent self-matches, self-match prevention, equity markets, exchanges, alternative trading systems, automated trading, liquidity, transaction costs, chilling effect, execution, Cross-Border, foreign markets, regulatory framework, corporate bonds, municipal securities, Ernst & Ernst v. Hochfelder, Santa Fe Industries Inc. v. Green, In the Matter of J.A. Latimer & Co. Inc., In the Matter of Thornton & Co., Manipulation, independent decision maker, market infrastructures, market data, market participants, aggregation units, trading desk,

Letter to the European Commission in Response to its Consultation Paper, Review of the Markets in Financial Instruments Directive (MiFID)02.02.11


MFA submitted comments to the European Commission in response to its Consultation Paper, Review of the Markets in Financial Instruments […]

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Topics: European Commission Markets in Financial Instruments Directive, MiFID, regulatory framework, market stability, risk capital, proprietary strategies, surveillance tools, European Union, EU, financial regulatory system, hedge funds, OTC, commodity derivatives market, Investor Protection, title transfer collateral arrangements, non-retail clients, third country firms, "strict equivalence" regime, electronic trading platforms, liquid derivatives, exchange trading, exchange-traded products, European OTC derivatives markets, US markets, Asian Markets, ESMA, sufficiently liquid, European Commission on Standardisation and Organised Platform Trading of OTC Derivatives, Organised Trading Venues, cost-effective manner, reduced transaction costs, algorithmic trading, broker dealers, market impact, accurate price discovery, high frequency trading, HFT, market makers, low latency technology, strategy holding periods, horizon strategies, fleeting arbitrage opportunities, risk management, electronic market-making, technology-driven market makers, inventory risk, risk exposure, inter-market arbitrage, ultra low-latency technology, capital formation, automated execution technology, global connectivity infrastructure, financial institutions, market connectivity intermediaries, direct market access, flash crash, HFT trades, non-HFT trade, asset managers, insurance companies, banks, brokers, automated trading, arbitraging, minimum quantitative threshold, portfolio manager, alternative investment fund managers, AIFM directive, UCITS Directive, level playing field, non-EU asset managers, risk controls, pre-trade checks, SEC, Securities and Exchange Commission, circuit breakers, market-wide single stock circuit breakers, limit up system, limit down system, speed bumps, trading delays, specified maximum execution speeds, co-location facilities, latency, liquidity, investor confidence, technological innovation, short-term price swings, low latency technology chain, minimum tick sizes, liquid market, deep market, liquidity provision requirements, article 4(8) of MiFID, broker-dealer capital, margin requirements, concentrated risk solution, regulatory "tax, market efficiency, minimum duration of orders, limit orders, stale orders, affirmative and negative obligations, pre-trade transparency, post-trade transparency, investment strategies, safeguards, equity markets, waivers, dark pools, equity investors, pre-trade transparency waivers, order stubs, alternative trading systems, ATSs, indications of interest, IOIs, actionable IOIs, block sized trades, daily trading volume threshold, order-slicing methodologies, price discovery, post-trade reporting proposals, depositary receipts, exchange traded funds, certificates, UCITS, non-EU markets, non-EU investment firms, MiFID framework directive, non-equity instruments, comprehensive price date, comprehensive notional data, regulatory transparency thresholds, data consolidation, approved publication arrangements, APAs, European Consolidated Tape, Consolidated Tape, Congress, National Market System, composite quotation system, consolidated transaction reporting system, quotations, Consolidated Tape Association, opaque market centers, sharp shoot, order flow, US Securities Industry Automation Corporation, national best bid and offer, depth of market quotations, reporting protocols, third party information vendors, Securities Industry and Financial Markets Association, NetCoalition, Yahoo Inc, Google, Bloomberg L.P., depth-of-market fees, NetCoalition v. Securities and Exchange Commission, core date, consolidated core data, CQ plan, position-level data, harmonised position information, reasonable threshold, nexus, trader ID, transaction report, confidentiality obligation, client identifier, statutory obligation, OTC contract, trade repository, summary disclosure, ex-post disclosure, ex-ante disclosure, conflicts of interest, title transfer collateral arrangement, retail client, member states, cash balance, risk warnings, securities financing transaction, information requirements, due diligence obligations, third country regime, equivalence mechanism, strict equivalence, market disorder, systemic risk, unilateral bans, market turmoil, cost/benefit analysis, regulatory authorities, consultation papers, systemic risk grounds, CCP, capital flows, lending flows, credit flows, International Swaps and Derivatives Association, ISDA, G20, Financial Stability Board, European Market Infrastructure Regulation, EMIR, sovereign CDS, European Commission's report of Sovereign CDS, credit default swaps, CDS market, hedgers, hard position limits, physical commodity markets, market manipulation, position management, mechanical imposition, commodity derivatives, CESR, UK Treasury and Financial Services Authority, price movement, derivatives position, Disclosure, reporting obligations, transparency directive, security-based derivatives, European Commission Request for Additional Information in relation to the Review of MiFID, volatility, non-hedging, aggregate open interest/notional amount, reporting regimes, contract, market data,

Comment Letter to SEC Responding to Concept Release on Equity Market Structure05.07.10


MFA submitted a letter to the SEC in response to its request for comments on its Equity Market Structure Concept […]

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Topics: Securities and Exchange Commission SEC, Equity Market Structure, order handling rules, regulation ATS, decimalization, Regulation NMS, institutional investors, retail investors, liquidity, bid-ask spreads, transaction costs, technology, non-public trading, risk management, broker dealers, capital formation, long-term investors, short-term traders, registered investment advisers, private investment pools, pensions, endowments, foundations, insurance companies, direct market access, sponsored access, low latency technology, high frequency trading, HFT, automated trading, investor confidence, trading volume, order cancellations, market maker, specialist quotes, algorithm, quantitative strategies, global financial crisis, frontrunning, order anticipation, public information, momentum ignition, dark pools, Office of Economic Analysis, post-trade execution, National Market System, electronic communication networks, ECN, alternative trading systems, Intermarket Trading System Plan, ITS, Nasdaq, electronically accessibel quotes, New York Stock Exchange, NYSE, U.S. Department of Justice, National Association of Securities Dealers Inc., proprietary trading, electronic trading desks, inventory risks, inter-market arbitrage, price discovery, spreads, fees, execution speed, market depth, efficiency, transparency, Japan, Germany, United Kingdom, France, hedging, Market Crash of 1987, asset classes, fixed income, buyers, sellers, market fragmentation, investment time horizon, capital allocation, mutual fund, trading desk, competitive barriers, U.S Treasury bonds, Treasury ETF, large cap stocks, small cap stocks, securities lending, quote flickering, phantom liquidity, cancellation rate, limit orders, order protection rule, market consolidation, Designated Market Maker, volatility, short selling, market color, trends, sector change, co-location, price swings, pinging, upstairs market, post-trade transparency, connectivity vendors,

MFA Comments to SEC on Interim Final Temporary Amendments to Regulation SHO12.15.08


MFA sent a letter to the SEC providing comments to the Commission’s interim final temporary rule on amendments to Reg […]

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Topics: Securities and Exchange Commission SEC, emergency orders, short selling, manipulative naked short selling, market dislocations, market participants, liquidity, public interest, efficiency, competition, capital formation, Financial Industry Regulatory Authority, FINRA, broker-dealer, naked short selling, pricing efficiency, Short Selling Activity in Financial Stocks, SEC July 15 Emergency Order, Arturo Bris, European Corporate Governance Institute, Yale International Center for Finance, three-day settlement cycle, capital raising, risk management, derivatives hedging strategies, hedging, distressed companies, capital, market risk, "delta" hedge, volatility, public companies, fails to deliver, securities, close-out, Voting Rights, prime broker, algorithmic trading, automated trading, manual trading, short selling regulation, clearing, settlement, uptick rule, sell-side firms, buy-side firms, hard to borrow shares, easy to borrow shares, locate, threshold securities list, threshold securities, self-regulatory organization, SRO, short positions, short squeeze, operational efficiency, bid-ask spreads, options, market maker, long sales, market efficiency, market liquidity, delivery, securities depositaries, custodian banks, executing brokers, Continuous Net Settlement, National Securities Clearing Corporation, NSCC, clearing agency, settlement date, market distortions, order to purchase, artificial buying pressure, borrowing costs, G19, G19 securities, Wall St. Journal, regulatory efficiencies, mandatory close-out, T+5, T+2, T+4, pre-fail credit, NYSE, New York Stock Exchange, debt securities, arrangement to borrow,
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