MFA Comment Letters

Topic: delivery

Comment Letter to SEC and CFTC on Proposed Rules Defining ‘Swap,’ ‘Security-Based Swap,’ and ‘Security-Based Swap Agreement,’ and Guidance on Mixed Swaps and Security-Based Swap Agreement Recordkeeping07.22.11


MFA submitted comments to the SEC and CFTC in response to their request for comments on their proposal on the […]

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Topics: 1993 energy exemption alternative delivery procedures, alternative transfer structure, antifraud liabilities, assignment and assumption agreements, bankruptcy estate, beneficial ownership interest, book-out contracts, business conduct requirements, capital, central clearing, CFTC, commodities, Commodity Futures Trading Commission, current debtor-creditor relationship, deferred shipment, delivery, direct or indirect ownership, eligible contract participants, energy commodities, exchange trading, Federal Securities Laws, forward contract exclusion, further definitions of swap, grantor, institutional investors, lender of record, liquidity, LMA, loan agreement, loan arrangers, loan market association, loan markets, loan participants, loan participations, loan payments, Loan Syndications and Trading Association, loan total return swaps, loan transfer mechanism, LSTA, margin, market participants, material non-public information, mixed swaps, netting, non-U.S. counterparties, nonfinancial commodity, oil, OTC derivatives, participant, participation agreements, physical commodity, physically settled, primary loan markets, private market, recordkeeping, reference loan, reporting, SEC, secondary loan markets, Securities and Exchange Commission, security, Security-Based Swap, security-based swap agreement, security-based swap agreement recordkeeping, syndicated loan market, synthetic exposure, systemic risk, total return payer, total return receiver, true participants, true participation, true sale, U.S. domiciled counterparties,

MFA Comments to SEC on Interim Final Temporary Amendments to Regulation SHO12.15.08


MFA sent a letter to the SEC providing comments to the Commission’s interim final temporary rule on amendments to Reg […]

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Topics: "delta" hedge algorithmic trading, arrangement to borrow, artificial buying pressure, Arturo Bris, automated trading, bid-ask spreads, borrowing costs, broker-dealer, buy-side firms, capital, capital formation, capital raising, clearing, clearing agency, close-out, competition, Continuous Net Settlement, custodian banks, debt securities, delivery, derivatives hedging strategies, distressed companies, easy to borrow shares, efficiency, emergency orders, European Corporate Governance Institute, executing brokers, fails to deliver, Financial Industry Regulatory Authority, FINRA, G19, G19 securities, hard to borrow shares, hedging, liquidity, locate, long sales, mandatory close-out, manipulative naked short selling, manual trading, market dislocations, market distortions, market efficiency, market liquidity, market maker, market participants, market risk, naked short selling, National Securities Clearing Corporation, New York Stock Exchange, NSCC, NYSE, operational efficiency, options, order to purchase, pre-fail credit, pricing efficiency, prime broker, public companies, public interest, regulatory efficiencies, risk management, SEC, SEC July 15 Emergency Order, securities, Securities and Exchange Commission, securities depositaries, self-regulatory organization, sell-side firms, settlement, settlement date, short positions, short selling, Short Selling Activity in Financial Stocks, short selling regulation, short squeeze, SRO, T+2, T+4, T+5, three-day settlement cycle, threshold securities, threshold securities list, uptick rule, volatility, Voting Rights, Wall St. Journal, Yale International Center for Finance,
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