MFA Comment Letters

Topic: Columbia University

MFA Submits White Paper to European Commission on Shadow Banking06.01.12


On June 1, MFA submitted a white paper on hedge funds and shadow banking in response to the European Commission’s […]

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Topics: "too big to fail ABCP conduits, absolute risk, AIFMD, Alternative Investment Fund Managers Directive, asset classes, asset-backed commercial paper conduits, asset-backed securities, assets under management, AUM, Background Note, Background Note "Shadow Banking: Scoping the Issues", bank-like activities, bank-like regulation, bankruptcy, banks, Board of Governors of the Federal Reserve System, broker-dealer, Brookings Institution, Bureau of Economic Analysis, central clearing, CFTC, chief compliance officer, collateral, Columbia University, commodity futures contracts, Commodity Futures Trading Commission, commodity pool, commodity trading advisor, convertible arbitrage, corporate bonds, corporate fixed income instrument, counter-cyclical, counterparties, credit arbitrage strategies, credit cards, credit hedge funds, credit intermediation, creditor, CTA, demand deposit accounts, Department of the Treasury, deposit-like characteristics, derivative transactions, derivatives, derivatives market, direct lending, direct loan market, discount windows, distressed restructuring strategies, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, Doug Elliott, EMIR, equity investors, EU, EU Member State, European Commission, European Market Infrastructure Regulation, European Union, financial industries, financial institutions, financial market, Financial Services Authority, Financial Stability Board, Financial Stability Oversight Council, fixed income - asset backed, fixed income - convertible arbitrage, fixed income - corporate, fixed income instruments, Form ADV, Form PF, FSA, FSB, FSOC, fundamental credit analysis, G20, gates, government bonds, government insurance, Green Paper "Shadow Banking", hedge fund counterparties, hedge fund industry, hedge fund managers, Hedge Fund Research, hidden leverage, House Financial Services Subcommittee on Financial Institutions and Consumer Credit, ICI, initial margin, insider trading, instant liquidity funds, institutional investment manager, investment advisers, Investment Company Institute, investment strategies, investor, leverage, leverage ratio, leveraged loan markets, liquidity, liquidity protections, liquidity transformation, loans, lock-up periods, Long Term Capital Management, Lord Adair Turner, major swap participants, margin, market based regulations, Markets in Financial Instruments Directive, Master Limited Partnership, maturity tra, maturity transformation, MiFID, money market funds, mutual funds, mutual funds management, non-bank financial insitutions, nonbank credit intermediation, Office of Financial Research, OFR, originator, OTC derivatives, over-the-counter derivatives, PIPE, pricing discrepancy, private equity, private investment in public equity, private issue/Regulation D strategies, property-casualty insurance, prudential regulation, public company equity securities, quantitative strategies, RAUM, real estate, receivables, redemption terms, Regulation D, regulatory arbitrage, regulatory assets under management, regulatory framework, relative value, relative value - multi-strategies, risk analysis, risk management, SEC, secured borrowings, secured financing, Securities and Exchange Commission, segregation, shadow banking, shadow banking system, side pockets, SIFI, SIV, small and medium-sized enterprises, SME, sophisticated investors, state securities regulators, structured investment vehicles, swap dealers, swaps, systemic risk, systemically important financial institution, tangible financial commitments, taxpayer, the Fed, total return swaps, transparency, U.S. Securities Laws, uncollateralized loans, United Kingdom, variation margin, venture capital funds, Volcker Rule,

Comment Letter to the CFTC on its Proposed Rules on Risk Management Requirements for Derivatives Clearing Organizations03.21.11


MFA submitted a comment letter to the CFTC on its proposed rules on Risk Management Requirements for Derivatives Clearing Organizations. […]

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Topics: $50 million upper limit antitrust considerations, Bank of America-Merrill Lynch, bilateral trades, capital requirements, CFTC, Chicago Board of Trade, cleared trade volumes, clearing member, clearinghouses, Columbia University, committee on payment and settlement systems and technical committee of the International Organization of Securities Commissions, Commodity Futures Trading Commission, competition, connectivity, counterparty credit assessment practices, CPSS-IOSCO standards, credit risk, creditworthiness, cross product margin, customer initial margin, DCM, DCO, DCO concentration risk, DCO margin methodologies, default management framework, derivatives clearing organizations, Designated Contract Market, differentiated margining, direct clearing members, direct clearing members' initial margin, diversity of market participants, effective date, electronic execution, eligibility standards, excess margin, executing counterparty, fair and open access, federal register, Federal Reserve Bank of New York, five-day liquidation horizon, futures, global banking crisis, greater market concentration, guaranty fund scaling methodologies, hedge fund industry, highly liquid instruments, initial margin, initial margin requirements, investment banks, ISDA, leverage ratio, mandatory central clearing, margin, margin calculation utility, margin calls, margin methodology, margin requirements, mark-to-market variations, market liquidity, market volatility, minimum capital requirements, net capital obligation, non-hedge positions, obligations, on-the-run 10 year interest rate swaps, participant eligibility, phase-in period, portfolio margining, product eligibility, product portfolio, risk exposure, risk management, Risk Management Requirements, risk-based methodologies, scaling requirements, SEC, Securities and Exchange Commission, SEF, standard two-way protocols, stress and default scenarios, Swap Execution Facility, swap portfolio, swap portfolio size, swaps, systemic risk mitigation, The Turner Review, threshold guaranty fund contribution, tiers, transaction volume, volatility,

Comment Letter Responding to SEC’s Proposal to Implement Amendments to the Advisers Act Contained in Title IV of the Dodd-Frank Act01.24.11


MFA submitted a comment letter todayto the SEC on its proposal to implement amendments to the Advisers Act contained in […]

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Topics: $1 Billion 11 and 12, 13 and 29, 15, 17, 5.D and 5.F, assets, assets under management, Bank of America-Merrill Lynch, banks, Basel Committee on Banking Supervision, beneficial owners, broker dealers, collateral, Columbia University, Commission on Form ADV, Committee on Financial Services, Compensation Structure, Compliance Risks, counterparties, Credit Unions, De Minimis Amount, Debt-to-Equity, Definition, Depository Institutions, Difficult-to-Value Assets, Duplicative Filing, effective date, Effective Date of Title IV, equity owner, European Central Bank, Excessive Compensation, Exemption, Fair Valu Hierarchy, Fair Value Methodology, Family Accounts, Form ADV, Form ADV Part 1A, Form ADV-T, FSA, GAAP, generally accepted accounting principles, Grandfathering Provisions, gross assets, Hearing on Industry Perspectives on the Obama Administration's Financial Regulatory Reform Proposals, hedge fund industry, Hedge Fund Manager Registration Rul, hedge fund managers, hedge funds, IARD, IARD System, Incentive-Based, Incentive-Based Compensation Arrangements, Income Thresholds, Instruction 5.b., Instruction 5.b(4), International Accounting Standards, investment adviser, Investment Adviser Registration Depository, Investment Management, Investor Protection Benefits, leverage, Leverage Ratios, Mid-Sized Manager, Mid-Sized Managers, National Securities Exchanges, net assets, NSMIA, Part 1A, performance fee, pooled investment vehicle, Portfolios, private adviser exemption, Private Fund Information, private fund managers, Proposed Instruction 1.b., Proposed Items 14, Proposed Items 5.A, Proprietary Accounts, Proprietary Accounts of the Manager, proprietary information, public disclosure, qualified client standard, qualified purchaser, registration, Registration Process, registration requirements, regulatory assets under management, Richard H. Baker, Schedule D, SEC, SEC-registered investment advisers, SEC-Registered Managers, SEC's Contract, Section 7.B.1, Securities and Exchange Commission, Securities Commissioner, state securities commission, Substantive Provision, systemic risk, Taxpayer Money, The Turner Review, threshold, Threshold of $25 Million, Tier 1 Financial Holding Company, transitional relief, U.S. House of Representatives, Unit-Linked Life Insurance, Unregistered Managers, Valuation Information, valuation methodology, venture capital funds, Wealth and Income Requirements,

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,

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,
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