MFA Comment Letters

Topic: CBOT

Comment Letter to the CFTC in Response to its Request for Comments on Position Limits for Derivatives03.28.11


MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains […]

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Topics: account aggregation requirements active trading program, aggregate all-months-combined, aggregate single-month, aggregate spot-month position limits, agricultural commodities, agricultural model, annual limits, annual recalculation methodology, annual renewal based exemption, application based exemption, approval based exemption, arbitrage exemption, Artificial limits, asset manager, audit, Barclays Capital, Bauer College of Business, benchmark contracts, Berlin wheat, bona fide hedger, calendar-spread exemption, cash market risk, cash market transaction, cash position, cash-settled contracts, CBOT, CFTC, CFTC docket no. 08-02, CFTC docket no. 11-05, Chicago onions, class limits, cleared bilateral contracts, CME, commercial hedgers, commercial participants, Commission Energy Complex Report, Commodity Futures Trading Commission, commodity market, commodity pool operator, commodity trading advisor, commodity trading advisors, common parent, conditional-spot month limit, control standard, corporate enterprises, CPO, Credit Agricole, cross-ownership of traders, crowding out provision, crude oil futures, CTA, CTFC Inter-Agency Task Force on Commodity Markets, DCMs, deferred month positions, deliverable supply, delivery point, delta, derivatives, directional position, disaggregation relief, disclosure documents, disorderly markets, eligible entity, energy market infrastructure, energy price volatility, Energy Risk, enforcement, enumerated agricultural commodities, equity interest, excessive speculation, FCMs, federal limits, financial cal spread options, financial institution, forward position, front month position, funds of funds, future commission merchants, futures, futures class all-months-combined, futures class single-month, futures market, GAO, global commodity, Global Energy Management Institute, hedge funds, hedging transaction, HH natural gas, HM Treasury Global Commodities, House Committee on Agriculture, hypothetical portfolios, IMF World Economic outlook, IMG, independent account controller exemption, independent third party, independently controlled accounts, independently controlled and managed trader, index fund manager, individual class rules, inter-commodity spread exemption, inter-commodity spread transactions, interest rates, International Organization of Securities Commission, interstate commerce, IOSCO, IOSCO Technical Committee, Jacks Study, JP Morgan, KCBOT, large trader data, last day swaps, legacy position limits, liquid price discovery, liquidity provisions, long positions, market depth, market liquidity, market manipulation, market surveillance, metal commodity, no-action relief, non-cleared bilateral contracts, non-financial entity exemption, non-spot position limits, NYBOT, NYMEX crude oil price, NYMEX Henery Hub Natural Gas contract, OECD Food, OECD publishing, offsetting positions, open interest, open interest formula, operating company, option contract, options, order routing arrangement, OTC, outright positions, passive investors, passive trading program, pension plan, penultimate swaps, percentage interest, physical cal spread options, physical commodity, physical commodity deliverable, physical options, physically delivered contracts, Pirrong Testimony, PKVerleger LLC, pool participant, pool participant exemption, position limits, position visibility, pre-existing position exemption, price discovery, price risk, price spikes, price volatility, private equity investments, real-time basis, referenced contracts, regulatory oversight, reporting obligation, reporting requirements, risk management, risk transfer, risk-shifting market, rounding, seasonal variation, seasonality, self-executing disaggregation, short positions, significant price discovery contracts, speculative investment, speculative trading ventures, spot month, spot-month position limits, squeezes, statement of reporting trader, stock indices, submarket, supply and demand, surveillance, swap contract, swap dealer hedge exemption, swaps class all-months-combined, swaps class single-month, swaptions, The Economist, U.S. dollar, U.S. futures exchange, UK Treasury, university endowment, University of Calgary, University of Houston, Wall St. Journal, WTI,

Comment Letter to CFTC Responding to Proposed Regulations to Implement Federal Speculative Position Limits for Futures and Options Contracts04.26.10


MFA submitted comments to the CFTC in response to its request for comments on its proposed rule on Federal Speculative […]

MFA Letter to FTC on Prohibition of Energy Market Manipulation Rule05.20.09


MFA jointly with FIA, CME Group, ICE and NFA submitted a letter to the Federal Trade Commission regarding its “Prohibition […]

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Topics: 1145 (7th Cir. 1982) 2002 WL 32135703, 2006 WL 778640 (S.D. Tex. March 24 2006), 250 N.W.2d 583 (Minn. 1976), 276 F.3d 583 (D.C. Cir. 2001), 276 F.3d at 591, 276 F.3d at 592, 420 F Supp.2d 1043 (N.D. Cal. 2006), 512 U.S. 594, 531 S.W.2d 805 (Tex. 1975), 537 U.S. 820, 546 F.2d 1361, 556 S.W.2d 420 (Ark. 1977), 677 F.2d 1137 (7th Cir. 1982), 706 (2d Cir. 1987), 823 F.2d 702, 883 F.2d 537 (7th Cir. 1989), accounts, Advanced Notice of Proposed Rulemaking, agents, agricultural feed-stocks, Agriculture Department, Amaranth, anti-manipulation protections, anti-manipulation system, Board of Trade of City of Chicago v. SEC, Board of Trade of City of Chicago v. SEC 677 F.2d 1137, Board of Trade of the City of Chicago, brokers, CBOT, CEA, CFTC, chain of precedent, Chciago Mercantile Exchange Inc., Chicago Mercantile Exch. v. SEC, Clayton Brokerage Co. v. Mouer, CME Group Inc., COMEX, commercial market, commodities, Commodity Exchange, Commodity Futures Trade Commission, commodity pool operators, commodity prices, commodity trading advisors, compliance burden, congressional grant, contract markets, contractual privity, contradictory requirements, corn, corporate disclosures, counterparties, crude oil, customer protection, DOE, Donald S. Clark, emissions credit, Energy Department, energy futures, energy markets, Environmental Protection Agency, EPA, ethanol, exclusive jurisdiction provision, exclusive jurisidiction provision, exclusive regulatory authority, false reports, Federal Energy Regulatory Commission, federal register, Federal Trade Commission, FERC, FIA, forward market business activities, fraud proscriptions, FTC, FTC v. Roberts, futures exchange, futures group, Futures Industry Association, gasoline, ICE, ICE Futures Canada, ICE Futures of Europe, ICE Futures U.S., Inc., instruments, IntercontinentalExchange, intermediaries, International Trading Ltd. v. Bell, Jeffrey Sprecher, Jerrold E. Salzman, John M. Damgard, Ken Roberts Co. v. FTC, limited-purpose national securities association, Manipulation, Market Manipulation Rulemaking, merchants, Minnesota v. Coin Wholesalers, National Futures Association, New York Board of Trade, new York Mercantile Exchange Inc., NFA, No. 01-1772, non-futures, non-petroleum based commodities, NYMEX, options trading, over-the-counter energy trading platform, Part 317, petroleum distillates, price artificiality, price discovery, price effects requirements, registered account executives, regulatory, resource limitations, safe harbor, SEC v. American Commodity Exch., SEC vs. Hopper, speculative limits, statutory authority, sugar, Thomas W. Sexton, Trichilo v. Sec'y of Health & Human Servs., U.S. Court of Appeals for the Seventh Circuit, United States Congress, US vs. Reliant Energy Services, USDA, wholesale markets, wholesale purchase, Williamson v. United States, Winnipeg Commodity Exchange,
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