MFA Comment Letters

Topic: duplicative regulation

MFA Letter to ESAs on EMIR Risk Mitigation Regulatory Technical Standards07.14.14


MFA submitted a comment letter to the European Supervisory Authorities (ESAs) on their joint consultation paper on “Draft regulatory technical […]

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Topics: AIMA alternative investment funds, Alternative Investment Management Association, base currency, Basel Committee for Banking Supervision, Canada, Cayman Islands, clearing threshold, collateral, collateral currency, concentration limits, consultation paper, Council of the European Union, counterparties, counterparty credit risk, dispute resolution procedures, documentation, duplicative regulation, efficiency, EMIR, equivalence, ESMA, European Banking Authority, European Commission, European Insurance and Occupational Pension Authority, European Market Infrastructure Regulation, European Parliament, European Securities and Markets Authority, European Supervisory Authorities, financial counterparties, France, G7, Germany, haircuts, harmonization, in-scope entity, Individual Segregation, initial margin, International Organization of Securities Commissions, International Swaps and Derivatives Association, IOSCO, ISDA, Italy, Japan, legal opinion, liquidation, liquidity, mandatory margin requirements, margin, market participants, minimum notional threshold, netting, non-financial counterparty, OTC derivatives market, proportionality principle, regulatory arbitrage, regulatory requirements, regulatory technical standards, securities, segregation, settlement currency, settlement period, substituted compliance, systemic risk, third country, third party custodian, trade repositories, trading costs, transparency, uncleared derivative, United Kingdom, United States, US Treasuries, variation margin, verification requirement,

MFA and AIMA Submit Joint Letter to CFTC on Further Proposed Cross-Border Guidance02.06.13


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (CFTC) on its “Further Proposed Guidance […]

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Topics: adviser registration AIMA, Alternative Investment Management Association, buy-side market participants, CCP, central clearing, central counterparty, CFTC, clearing, collective investment vehicles, commodities, Commodity Futures Trading Commission, commodity pool, commodity pool operator, Corporation, Council of the European Union, CPO, CPPSS-IOSCO, Cross-Border, de minimis, Dealer, derivatives, direct or indirect ownership, Dodd-Frank Act, duplicative regulation, ESMA, estate, EU, European Parliament, European Securities and Markets Authority, European Union, execution, foreign regulators, Form CPO-PQR, fund of funds, G20, G20 commitments, Gary Gensler, hedge fund managers, Hong Kong, Hong Kong Monetary Authority, income tax, international harmonization of regulations, International Organization of Securities Commissions, interpretive guidance, investment fund, investment manager, IOSCO, joint-stock company, Limited Liability Company, limited liability partnership, listed entity, LLC, LLP, Look Through, Major Swap Participant, majority ownership, mandatory clearing requirements, market participants, Mary Schapiro, MAS, Monetary Authority of Singapore, msp, OCC, Office of the Comptroller of the Currency, OTC derivatives, OTC derivatives market, OTC derivatives reform, over-the-counter derivatives, ownership test, partnership, pension, phase-in period, pooled accounts, prime brokers, principal place of business test, registration, regulatory framework, SEC, Securities and Exchange Commission, Singapore, swap dealer, swaps, systemic risk, trade repositories, transparency, Trust, U.S. person,

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its “Proposed Interpretive Guidance […]

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Topics: accredited investors African Development Bank, AIMA, Alternative Investment Management Association, Asian Development Bank, banks, Business Conduct Standards, buy-side firms, CFTC, chief compliance officer, clearing, collective investment vehicles, comment letter, Commodity Futures Trading Commission, commodity pool, commodity pool operator, commodity swaps, compliance costs, Corporation, cost-benefit analysis, Council of the European Union, counterparties, CPO, CPO registration requirements, Dealer, dealers, Department of the Treasury, derivatives, derivatives markets, direct or indirect ownership, duplicative regulation, entity-level requirement, ESMA, estate, European Parliament, European Securities and Markets Authority, execution, fiduciary, financial crisis, financial stability, financial system, foreign banks, foreign entity, Form CPO-PQR, fund, fund of funds, G20, G20 commitments, general partnerships, hedge fund administrator, hedge fund industry, hedge fund managers, Hong Kong, Hong Kong Monetary Authority, income tax, Inter-American Development Bank, International Bank for Reconstruction and Development, international harmonization of regulations, International Monetary Fund, International Organization of Securities Commissions, interpretive guidance, IOSCO, Jill Sommers, joint-stock company, limited liability companies, listed entity, Look Through, major swap participants, majority ownership, margining, market impact, market participants, Monetary Authority of Singapore, MSPs, natural person, non-U.S. investment fund, non-U.S. market participants, non-U.S. persons, OTC derivatives, OTC derivatives market, over-the-counter derivatives, partnership, pension plans, Policy Makers, pooled accounts, portfolio reconciliation, prime brokers, qualified eligible person, real-time public reporting, registration, regulatory framework, regulatory requirements, reporting party, risk management, Scott O'Malia, SEC, Securities and Exchange Commission, Securities and Futures Commission, segregation, sell-side firms, shareholders, Singapore, substituted compliance, swap data recordkeeping, swap data reporting, swap data repository, swap dealer, swaps, swaps processing, third country, trade confirmations, transaction cost, transaction-level requirements, transparency, Trust, U.S. person, uncleared swaps, United Nations,

MFA Submits Letter to ESMA on Draft Technical Standards on OTC Derivatives08.05.12


MFA submitted a comment letter to the European Securities and Markets Authority (“ESMA”) in response to its Consultation Paper on “Draft Technical […]

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Topics: "delta" hedge administrator, affiliated market participants, agency basis, Asia, back testing, Basel Committee on Banking Supervision, Basel III, bespoke non-cleared trades, bilateral counterparty credit risk, bilateral non-cleared OTC derivatives transactions, capital, CCP, CCP governing bodies, CDS, central clearing, central counterparty, CFTC, clearing member, client protections, close-out, collateral, Commodity Futures Trading Commission, compliance, confidence interval, conflicts of interest, contractual relationship, Council of the European Union, counterparty risk, coupon, CPSS-IOSCO, CPSS-IOSCO standards, credit default swap, credit institutions, credit risk, Cross-Border, currency, Dealer, debt-security based swaps, default, default fund, Derivative Contracts, derivatives, derivatives contracts, direct client, Dodd-Frank Wall Street Reform and Consumer Protection Act, duplicative regulation, EMIR, ESMA, EU, EU Member State, Euro, Europe, European Parliament, European Securities and Markets Authority, European Union, execution, extraterritorial application of EMIR, extraterritoriality, fiduciary duty, financial instrument, floating rate payment, foreign exchange, gross basis, hedging, in-the-money swap, index, indirect clearing, indirect client, initial margin, interest rate derivatives, interest rate swaps, interlocking governance arrangements, internal controls, International Organization of Securities Commissions, interpretive guidance, IOSCO, LCH Clearnet, Lee Underwood, liquidation horizons, liquidity fragmentation, major swap participants, margin, margin requirements, margin valuation, market participants, maturity, money market instruments, mutual recognition, negative correlation, net basis, netting, non-cleared OTC derivatives, non-linear products, omnibus account, OTC derivatives, OTC derivatives market, OTC derivatives transactions, over-collateralization, over-the-counter derivatives, portability, portfolio compression, portfolio reconciliation, posted collateral, principal basis, Proprietary Trading Strategy, proprietary trading tools, public disclosure, Regulators, regulatory arbitrage, regulatory technical standards, risk committee, risk management, risk management framework, risk mitigation, risk profile, SEC, Securities and Exchange Commission, security-based swaps, segregation, self-regulatory organization, settlement prices, SRO, Stan Ivanov, straight-through processing, stress testing, swap dealers, swaps, systemic risk, third country regime, total return swaps, trade repositories, trading costs, trading venues, transaction fees, transparency, upfront payment, variation margin,

MFA Submits Comments to the Monetary Authority of Singapore on Proposed Regulations on OTC Derivatives03.26.12


MFA submitted a comment letter to the Monetary Authority of Singapore (MAS) in response to its Consultation Paper on Proposed […]

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Topics: aggregate counterparty credit risk average notional value, backloading, barriers to entry, bilateral market, buy-side clearing, CCP, central clearing, central counterparty, CFTC, clearing, clearing arrangements, clearing facilities, clearing house, clearing threshold, client access to clearing, commercial banks, Commodity Futures Trading Commission, confidentiality, Consultation Paper on Proposed Regulation of OTC Derivatives, counterparty identification, counterparty risk, customized and proprietary investment strategies, dealers, derivatives transactions, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, duplicative regulation, efficient capital flows, ESMA, EU, European Commission, European Union, financial entities, Financial Stability Board, foreign regulator, Form PF, fragmentation of liquidity, FSB, G20, G20 commitments, Gary Gensler, Honk Kong Monetary Authority, intellectual property, international harmonization of regulations, International Organization of Securities Commissions, IOSCO, legal entity identifiers, liquid and standardized transactions, liquidation horizons, mandary clearing, margin determinations, margin methodologies, margin requirements, market participants, Mary Schapiro, MAS, Monetary Authority of Singapore, money changers, netting, non-centrally cleared derivatives transactions, non-dealer client representation, non-financial entities, OTC derivatives, OTC derivatives market, over-the-counter derivatives, real-time processing, recognized clearing houses, registered insurers, regulatory regime, risk committees, risk management, Securities and Exchange Commission, Securities and Futures Commission, settlement risk, Singapore, straight-through processing, swaps, systemic risk, trade repositories, trading costs, trading mandate, transaction data, U.S. Federal Reserve Bank of New York, U.S. Senate Committee on Agriculture Nutrition and Forestry,
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