MFA Comment Letters

Topic: chilling effect

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

Click to expand relevant topics

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

MFA Submits Comments to USTR on Mexican Bankruptcy Law for Trade Negotiations09.04.12


MFA submitted comments to the U.S. Trade Representative (“USTR”) raising concerns with the Mexican Business Reorganization Act as demonstrated by […]

MFA Submits Amicus Brief on Issue of Creditor Coordination06.29.12


On June 29, MFA filed an amicus brief in the 11th Circuit en banc review of the CompuCredit case.  At […]

Click to expand relevant topics

Topics: Aidan Synnott Ali Stoeppelwerth, alternative investment industry, anticompetitive, Arizona v. Maricopa County Medical Society, Bankruptcy Code, Bankruptcy Filing, banks, bilateral monopoly, Board of Governors of the Federal Reserve System, Bondholder, bonds, borrowers, Brendy Kuehne, Broad. Music Inc. v. Columbia Broadcasting Sys. Inc, broker-dealer, Bus. Elecs. Corp. v. Sharp Elecs. Corp., capital, capital formation, chilling effect, Classic Cheesecake Co. Inc. v. JPMorgan Chase Bank NA, collective action risks, competition, Compucredit Holdings Corporation v. Akanthos Capital Management LLC, Conrad Duberstein, contract, contractual relationship, corporate bonds, credit market, credit squeeze, creditor, creditor coordination, Daniel Crane, debt instruments, debtor, distressed debt, Edward Altman, Falstaff Brewing Corp. v. New York Life Ins. Co., FDIC, Federal Deposit Insurance Corporation, Federal Trade Commission v. Brown Shoe Co., Federal Trade Commission v. Indiana Federation of Dentists, Federal Trade Commission v. Superior Court Trial Lawyers Association, Financial Crisis Inquiry Commission, Finnegan v. Campeau Corp., Glenn Merrick, hedge funds, high-velocity market, institutional lender, interest rates, investment banks, Ireland v. Craggs, John Coffee Jr., Judge Easterbrook, Leegin Creative Leather Products Inc. v. PSKS Inc., leverage, Loan Syndications and Trading Association, low-velocity market, Marcel Kahan, Maris Distrib. Co. v. Anheuser-Busch Inc., market power, maturity date, Michael MacKenzie, Moses Silverman, National Collegiate Athletic Association v. Board of Regents, New York University Salomon Center, Nicole Bullock, Northwest Wholesale Stationers Inc. v. Pacific Stationery & Printing Co., Office of the Comptroller of the Currency, Palmyra Park Hosp. Inc. v. Phoebe Putney Memorial Hospital, par value, per se rules, pre-packaged bankruptcy, price competition, price-fixing, primary market, Reisner v. General Motors Corp., Reiter v. Sonotone Corp., risk portfolio, secondary loan markets, securities firms, Securities Industry and Financial Markets Association, Shared National Credit Review, Sharon Steel Corp. v. Chase Manhattan Bank NA, SIFMA, Smith v. The Ferncliff, State Farm Mutual Auto. Ins. Co. v. Physicians Injury Care Center Inc., Stern School of Business, syndicated loan market, systemic risk, Tomotaka Fujita, Twin City Pipe Line Co. v. Harding Glass Co., U.S. Court of Appeals for the Eleventh Circuit, U.S. Court of Appeals for the Second Circuit, U.S. Court of Appeals for the Seventh Circuit, Unijax Inc. v. Champion International Inc., United Airlines Inc. v. U.S. Bank NA, United States v. Giordano, United States v. Topco Assocs Inc., Volt Info. Scis. Inc. v. Board of Trs. of Leland Stanford Jr. University, William Klein,

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 […]

Click to expand relevant topics

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 Comments to SEC on Pay to Play Proposal10.06.09


MFA submitted a letter to the SEC today in response to its proposal to, among other things, restrict political contributions […]

Click to expand relevant topics

Topics: academic institutions affiliated broker-dealer, agency, American Bar Association, anti-competitive effects, assets, authority, backward-looking provisions, beneficial owners, Broker, broker-dealer, California Public Employees' Retirement System, CalPERS, CalSTRS, cash solicitation, charitable institution, chief compliance officer, chilling effect, code of ethics rule, Committee on Federal Regulation of the American Bar Association, compensation arrangements, compliance burden, compliance costs, compliance procedures, Connecticut, contractual rights and obligations, covered associates, covered investment pool, de minimi exception, Dealer, direct investment, direct investors, Disclosure, disproportionately severe punishment, due diligence, executive officer, family members of covered associates, fiduciary duty, Form ADV, Foundation, fund assets, fund of funds, general partner, government assets, government entities, government official, hedge fund managers, hedge funds, Illinois, inadvertent contribution, Inadvertent Violation, inauguration or transition committee, incentive fee structure, institutional investor, instrumentality of the State, interest, investment adviser, investment advisory services, investment management industry, investment management services, investment objectives, investment services, investment techniques, legal authorities, limited partnership, liquidity, local or state political party, look-back period, look-back provision, Los Angeles City Employees' Retirement System, Los Angeles County Employees' Retirement System, management fees, marketing activities, Massachusetts, MSRB, municipal securities, municipal securities business, municipal securities principals, municipal securities professional, municipal securities representative, Municipal Securities Rulemaking Board, municipal securities underwriters, municipal underwritings, New Mexico Educational Retirement Board, New Mexico Investment Council, New York, New York City Employees' Retirement System, New York State Common Retirement Fund, offshore managers, Oklahoma, operational challenges, pay to play practices, pay to play scandals, Pennsylvania Public School Employees' Retirement System, Pennsylvania State Employment Retirement System, pension, personal political activities, placement agent, plan, platform arrangement, political action committee, political contributions, pool of assets, pooled investment vehicle, portfolio manager, pre-approval policies, pre-approval procedures, principal business unit, private fund, program, public pension plans, publicly offered securities, redemption requests, redemption rights, registered investment adviser, registered investment companies, registration, regulations, Regulators, requests for proposals, returned contribution, risk management, sales principals, SEC, Securities and Exchange Commission, securities firms, soliciting, state and federal laws, state and local entities, Teacher Retirement System of Texas, third party placement agent, third party placement agents, third party solicitors, transparency, unregistered adviser, Wall St. Journal, Washington, written compliance policies and procedures,

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 […]

Click to expand relevant topics

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,
Results 1 - 10 of 12