MFA Comment Letters

Topic: cleared swaps

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 […]

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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 SEC Supporting ICE Clear Credit’s Portfolio Margining Petition06.13.12


MFA submitted a comment letter to the SEC in support of ICE Clear Credit LLC’s portfolio margining petition.  In the […]

Comment Letter to CFTC on Proposed Rules Governing Protection of Cleared Swap Customer Contracts and Collateral08.08.11


MFA submitted a comment letter to the CFTC in response to its notice of proposed rulemaking on Protection of Cleared […]

Letter to Mary Schapiro; Attachments: (Industry Letter on Buy Side Access to Clearing) and (Recommended Timeline for Adoption and Implementation of Final Rules Pursuant to Title VII of The Dodd-Frank Act)03.24.11


MFA submitted a letter to Chairmen Schapiro and Gensler, and each of the SEC and CFTC Commissioners, providing our recommendations […]

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Topics: 14d order 17f6 order, alternative margin segregation schemes, asset manager accounts, asset managers, back loading facility, back-office processing, Bankruptcy Code, Basel I capital requirements, big bang approach, bilateral swaps, block trade. swap initial margin, block trading, Bloomberg, broad industry clearing, broad-based index credit default swaps, Business Conduct Standards, buy-side access, buy-side participants, capital requirements, CCP implementation period, CCP risk management, CCPs, CDS, CDS books, central clearing, CFTC rules, clearable contracts, cleared OTC derivatives, cleared settlement, cleared swaps, clearing, clearing agreement, clearing members, clearinghouses, ClearPort, CME, CME rules, CMs, collateral, commission fee, commodity contracts, complex instruments, compression, counterparty risk, credit, current clearable swaps, customer clearing services, customer funds, DCO governance, DCO registration, dealer-to-dealer clearing, default waterfall, derivatives clearing organizations, direct clearing participants, Dodd-Frank clearing requirements, DTCC data, efficiency, electronic data, eligible contract participant, end to end production testing, end-to-end systems flow, end-user exemptions, end-users, English law CSAs, exchange trading, execution agreement, fallback processing, FCMs, FIA, financial disclosure requirements, FINRA exemptions, front-office processing, future clearable swaps, futures, give up process, give-up agreements, global financial system, hedge funds, ICELink, IIGC, indirect clearing participants, individual risk concentrations, industry-level metrics, interdealer reporting, interest rate markets, interest rate swaps, investor, ISDA Governance Committee, liquid contracts, liquid swap transactions, liquidity, long-only accounts, mandatory clearing date, margin methodology, margin regime, margin requirements, margin segregation, MarkitWire, middle-office processing, migration, milestones, mixed swap, MSP recordkeeping requirements, MSPs, net client omnibus margin account, New York Fed, non-US bankruptcy, non-US bankruptcy laws, non-US CM's default, onboarding, onboarding work streams, open interest caps, OTC derivatives, OTC derivatives market, OTC derivatives reform, Phase 1 mandatory cleared products, phase-in approach, phase-in period, position limits, post-default portability, post-trade reporting, pre-default portability, pre-trade reporting, price challenge protocol, price transparency, public reporting, real-time reporting, reform, Regulators, risk compression, risk waterfall process, roll-out schedule, scale readiness, SD recordkeeping requirements, SEC exemptions, SEC rules, Securities and Exchange Commission, SEF trading, segregation framework, sell-side firms, simpler instruments, single-name CDS, standardized documentation, standardizing contracts, streamlined netting process, swap dealer, systemic counterparty risk, systemic risk, TBF, tear-ups, title transfer regime, trade compression, trade rejection rights, trade repositories, trade repository data, trade transparency, trading annex, transparency, uncleared settlement, US bank CM, US banking regulators, US bankruptcy, vendor, volume targets, voluntary back loading, voluntary period, voluntary targets, waterfalls,

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. […]

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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,

MFA Comments on CFTC Regulatory Intitiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

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Topics: "too big to fail AIG, bankruptcy law, Bondholder, business risk, capital markets, CCP, central clearing, central counterparties, CFTC, cleared swaps, clearing, collateral, Columbia University, commercial paper, Commodity Futures Trading Commission, commodity pool operator, commodity trading advisor, contract market, Counterparty, credit exposure, creditor, CTA, customer asset, customer protection, depositor, Designated Contract Market, endowments, equity market, FCM, FDIC, Federal Deposit Insurance Corporation, Federal Financial Institutions Examination Council, Federal Reserve, financial crisis, financial regulatory system, financial risk, Financial Stability Oversight Council, FSOC, futures, futures commission merchant, futures market, hedge funds, individual account, initial margin, institutional investors, international coordination, investment adviser, Investment Company Institute, investment portfolio, investor confidence, Investor Protection, leverage, liquidity, Major Swap Participant, managed funds, market discipline, market integrity, market maker, market stability, msp, non-bank MSP, non-swap dealer, Office of Financial Research, offsetting position, omnibus account, operational risk, OTC derivatives market, over-the-counter derivatives market, owned funds, Peavey Commodity Futures Fund no-action letter, pension plans, physical market, position limits, private investment funds, proprietary asset, proprietary strategies, regulatory capital requirements, reporting, residual value, risk capital, risk committee, risk management, risk model, roll-over, SEC, Securities and Exchange Commission, security-based swaps, SEF, segregation, substantial position, swap, swap dealer, Swap Execution Facility, systemic risk, TARP, third party custodian, Tier 1 capital, transparency, Troubled Asset Relief Program, U.S. Banking Industry, uncleared swaps, variation margin,

MFA Comments on SEC Regulatory Initiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

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Topics: "too big to fail accredited investor, AIFs, AIG, alternative investment funds, Bad Actors, bankruptcy law, beneficial ownership, Bondholder, Broker, business risk, capital formation, capital markets, CCP, central clearing, central counterparties, CFTC, cleared swaps, clearing, client, collateral, Columbia University, commercial paper, Commodity Futures Trading Commission, commodity pool operator, commodity trading advisor, Comptroller General of the United States, Confidential Information, contract market, Counterparty, covered financial institution, credit exposure, creditor, CTA, CUSIP number, customer asset, customer protection, depositor, Designated Contract Market, Disclosure, disqalifying felons, EC, endowments, EP, equity market, EU, European Commission, European Commissioner Michel Barnier, European Council of Finance Ministers, European Parliament, European Union, executive compensation, family office, FCM, FDIC, Federal Deposit Insurance Corporation, Federal Financial Institutions Examination Council, Federal Reserve, fiduciary, fiduciary standard, financial crisis, financial entities, financial regulatory system, financial risk, Financial Stability Oversight Council, Form SH, FSOC, futures, futures commission merchant, futures market, global banks, global market, hedge funds, herding, Incentive-Based Compensation Arrangements, individual account, initial margin, institutional investors, international coordination, investment adviser, investment adviser examination, Investment Company Institute, investment portfolio, Investor Advisory Committee, investor confidence, Investor Protection, knowledgeable employees, leverage, liquidity, Major Security-Based Swap Participant, Major Swap Participant, managed funds, many-to-many platform, margin requirement, market discipline, market integrity, market maker, market makers, market stability, msp, MSSP, mutual fund, non-bank financial companies, non-bank MSP, non-swap dealer, OCIE, Office of Compliance Inspections and Examinations, Office of Financial Research, offsetting position, omnibus account, operational risk, OTC derivatives market, over-the-counter derivatives market, owned funds, Peavey Commodity Futures Fund no-action letter, pension plans, performance reports, physical market, pooled investment vehicle, pooled vehicle, position limits, price discovery, Price Manipulation, private funds, private investment funds, proprietary asset, proprietary information, proprietary strategies, qualified client, registration, Regulation D, regulatory capital requirements, reporting, residual value, retail clients, retail funds, risk capital, risk committee, risk management, risk model, risk profile, roll-over, SEC, SEC-registered advisers, Secretary Geithner, Securities and Exchange Commission, security-based swaps, SEF, segregation, self-regulatory organization, short selling, short swing profit reporting, SRO, substantial position, swap, swap dealer, Swap Execution Facility, systemic risk, TARP, third party custodian, Tier 1 capital, transitional relief, transparency, Troubled Asset Relief Program, U.K. Chancellor of the Exchequer Alistair Darling, U.S. Banking Industry, uncleared swaps, variation margin, Venture Capital Fund, volatility,
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