MFA Comment Letters

Topic: CESR

MFA and AIMA Submit Joint Letter to ESMA in Response to Call for Evidence on Short Selling Regulation03.15.13


MFA and AIMA jointly submitted a comment letter to ESMA responding to its Call for Evidence regarding its evaluation of […]

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Topics: AIFMD AIMA, Alternative Investment Management Association, assets under management, AUM, BaFin, Belgium, bid-ask spreads, bond, Bundesanstalt fur Finanzdienstleistungsaufsicht, capital, CDS, CESR, Commissione Nazionale per le Societa e la Borsa, Committee of European Securities Regulators, competent authorities, compliance, corporate issuer, Council of the European Union, credit default swap, delta, depositary receipts, derivative instrument, derivatives, duration, efficiency, EMIR, equity, ESMA, EU Member State, Europe, European Commission, European Parliament, European Securities and Markets Authority, eurozone, extraterritoriality, Finland, France, futures, futures market, Germany, harmonization, hedge funds, hedging, index, index derivatives, interpretive guidance, issued share capital, Italy, Latvia, Lehman Brothers, liquidity, locate, London Stock Exchange, mark-to-market, market disruption, market distortions, market participants, MiFID, net short position, Netherlands, non-EU investment firms, operational challenges, price discovery, price efficiency, price formation, prime broker, PRNewswire, public disclosure, reasonable expectation, reporting obligation, reporting requirements, reverse engineer, risk, securities, settlement, share capital, short positions, short selling, short selling bans, short selling regulation, short squeeze, single-name CDS, sovereign bonds, sovereign debt, sovereign issuer, Spain, Steven Maijoor, stock, Stock Exchange Daily Official List, T+1 reporting, T+2, technical standards, third party managers, trading volume, uncovered sovereign CDS, United Kingdom, volatility,

MFA Submits Comments to ESMA on Short Selling and Sovereign CDS03.09.12


MFA submitted comments in response to ESMAs public consultation on possible delegated acts concerning the Regulation on short selling and […]

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Topics: aggregation of positions AIFMD, Alternative Investment Fund Managers Directive, anti-avoidance provision, anticipated correlation, asset managers, Austria, bank name CDS, Belgium, BNP Paribas, broad-based indices, buffer periods, Buttersworth Journal of International Banking and Financial Law, CDS transaction, central clearing, CESR, civil law, clearing house, consolidated accounts, contract of insurance, convertible bond positions, convertible bonds, convertible debt, convertible debt securities, corporate bonds, correlation test, credit default swap, credit protection, credit quality, debt instruments, default risk, delegate, delta adjusted method, derivative instrument, disaggregation, emergent systemic risk, ESMA, ETF, EU Member State, European Securities and Markets Authority, Eurostoxx, eurozone, Financial Agency of Spain, financial institutions, financial instrument, forward rate agreement, France, FSA, fund management activities, future, Greece, group, hedged portfolios, holding a share, ICO, illiquid shares, indices, indirect exposures, Instituto de Credito Oficial, insurable interest, interest rate swap, interest rates, intra-Member State correlation, Ireland, IRS, IRS curve, issued share capital, Italian CDS, Italian CONSOB, Italian lira, Italy, legitimate market operations, Leonard Ng, Level 2 process, liquid market price, listed securities, long positions, margin level, market participants, Markit iTraxx SovX Western Europe Index, maturity bucket, Member State regulator, Ministry of Economy and Finance, money market instruments, narrow-based indices/baskets, natural or legal person, net short positions, netting, notional basis, option, OTC instruments, pan-European short selling disclosure regime, Portugal, proprietary models, publicly available information, quantitative threshold for high correlation, RBS, redenomination, reference asset, Regulation on short selling and certain aspects of credit default swaps, Secretariat of State for the Economy, sector-specific, securities law, sensitivity adjusted method, severe market turmoil, short sale, short selling, short selling bans, Societe Generale, sovereign bonds, sovereign CDS, sovereign CDS transactions, sovereign debt, sovereign issuer, Spain, static or dynamic hedging strategy, subordinated debt, supra-national European body, swap, tail risk, tail risk hedging, threshold of liquidity, trust preferred securities, UCITS, UK Financial Services Authority, uncovered credit default swap, uncovered position, uncovered short sales and credit default swaps, underlying shares, yield curve,

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

MFA Comments on Consultation on Increasing Short Position Transparency10.09.09


MFA submitted a letter to the Hong Kong Securities and Futures Commission (SFC) today in response to its Consultation Paper […]

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Topics: alternative investment classes anonymised disclosure, bid-ask spreads, capital formation, capital raising, cash markets, CESR, chilling effect, close out indicators, confidentiality, convertible arbitrage, convertible bonds, copycat behavior, delta adjusted, derivatives, designated securities, dual-listed securities, efficiency, endowments, exchange trading, Financial Services Authority, financial services sector, financial stocks, foundations, FSA, global equity markets, hedging strategies, herding, Hong Kong, Hong Kong market, institutional investors, investment managers, Journal of Finance, liquidity, listed corporations, manipulative conduct, market efficiency, market liquidity, market making, market participants, market volatility, net long position, net short positions, non-designated securities, non-public disclosure, off-exchange transaction, on-market transactions, OTC transaction, pan-European short selling disclosure regime, pensions, price discovery, price formation, price volatility, primary market, private reporting, proprietary research, public disclosure of short positions, reporting threshold, retail investors, risk management, SEC, Securities and Exchange Commission, Securities and Futures Commission, SEHK, settlement, SFC, short positions, short sellers, short selling, short selling bans, short selling disclosure regime, short squeeze, stocks, transaction costs, transitory short position, transparency, turnover ratio, volatility,

MFA Response to CESR Consultation Paper on a Proposal for a Pan-European Short Selling Disclosure Regime10.01.09


MFA submitted a letter to the Committee of European Securities Regulators (CESR) today in response to its Consultation Paper on a […]

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Topics: 130/30 funds absolute return strategies, abusive behavior, abusive practices, abusive short selling practices, academics, aggregated anonymised data, aggregation, alternative investment classes, alternative investment industry, alternative investment managers, alternative investment vehicles, asset management company, basket trade, bid-ask spread, capital formation, capital markets, capital raising, CESR, CESR Proposal for a Pan-European Short Selling Disclosure Regime, chilling effect, Committee of European Securities Regulators, competent authorities, confidentiality, convertible arbitrage, convertible bonds, convertible securities, Credit Suisse, cumulative compliance costs, de minimis, delta adjusted, derivative positions, derivatives, disclosure thresholds, disproportionate costs, EEA equities, EEA stock, endowments, enhanced transparency, equity markets, EU, EU Member State, European markets, European Union, exchanges, exposures, extraterritoriality, extreme market conditions, financial institutions, Financial Regulatory Authority, financial services sector, financial stocks, FINRA, flagging regime, flagging short sales, foundations, free flow of information, freedom of information regimes, FSA, fund of funds, global capital markets, global equity markets, harmonization, hedge, hedge funds, hedging strategies, herding, hybrid funds, index trading, industry service providers, institutional investors, investment managers, investors, Issuer, Journal of Finance, large-scale short selling, liquidity, long equity positions, managed futures funds, manipulative conduct, Market Confidence, market efficiency, market maker, market making, market participants, market stability, market testing, market volatility, materially negative impacts, meaningful data, Member State competent authorities, MiFID, naked short selling, negative returns, net economic short position, net economic short positions, over-the-counter transactions, Pension Funds, physical short sales transactions, price amplification, price declines, price discovery, pricing efficiency, private reporting, professional secrecy, prudential regulators, public disclosure of short positions, real time information, reporting regimes, retail investors, Reverse Engineered, risk management, risk management function, securities prices, settlement, share issues, short equity position, short positions, short selling, short selling bans, short selling disclosure regime, short selling prohibitions, short squeeze, significant adverse effect, stability, T+1 reporting, timeframe for reporting, trading platform, trading strategies, traditional bond issuance, transaction costs, transitory short position, transparency directive, two-tier disclosure model, UK Financial Services Authority, Unwind,

MFA Comment Letter to the Committee of European Securities Regulators in Response to its Call for Evidence on Mutual Recognition with Non-European Union Jurisdictions09.04.09


MFA submitted a letter to the Committee of European Securities Regulators today in response to its Call for Evidence on mutual […]

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