MFA Comment Letters

Topic: end-users

MFA Submits Comment Letter to CFTC on Margin Requirements12.02.14


On December 2, MFA submitted a comment letter to the Commodity Futures Trading Commission (CFTC) to issue final margin requirements […]

MFA Coalition Submits Joint Letter to SEC and CFTC on CDS Customer Portfolio Margining05.10.13


MFA, the American Council of Life Insurers (ACLI), and the Alternative Investment Management Association (AIMA) (collectively, the “Associations”) submitted a […]

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Topics: ACLI AIMA, Alternative Investment Management Association, American Council of Life Insurers, arbitrage, backloading, broad-based indices, broker-dealer, buy-side participants, capital, capital formation, CDS, central clearing, CFTC, clearing, clearing agency, clearing mandate, clearinghouse, collateral, Commodity Futures Trading Commission, counterparty credit risk, counterparty risk, credit default swaps, credit risk, custody bank, DCM, DCO, dealers, derivatives, derivatives clearing organization, direct clearing members, directional portfolio, economic barriers, end-users, equity markets, excess margin, FCM, Federal Reserve Bank of New York, Financial Industry Regulatory Authority, FINRA, futures commission merchants, Gary Gensler, hedging, ICE Clear Credit LLC, ICE Trust, initial margin, initial margin requirements, insolvency, institutional custodian, interconnectedness, interest rate swaps, Investor Protection, iTraxx Europe, legal segregation with operation commingling, liquidation, liquidity, liquidity requirements, long-short strategies, LSOC, LSOC with excess, margin, margin requirements, margining, market efficiency, market participants, Mary Jo White, master netting agreements, narrow-based index credit default swap, net margin, New York State Banking Department, OCC, offsetting position, Options Clearing Corporation, portfolio margining, price competition, price distortion, proprietary strategies, registered clearing agencies, regulatory framework, risk management, S&P 500, SEC, Securities and Exchange Commission, security-based swaps, segregation, self-clearing members, sell-side firms, settlement, short straddles, single-name CDS, speculative position, straight-through processing, swaps, systemic risk, tri-party segregation arrangements, variation margin, volatility, voluntary clearing,

MFA Submits Accompanying Portfolio Margining Letter11.26.12


MFA submitted a supplemental comment letter to the U.S. prudential regulators during the reopened comment period for their proposed rulemaking […]

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Topics: affiliate-held collateral bankruptcy, Board of Governors of the Federal Reserve System, broker-dealer, buy-side, capital markets, capital requirements, caps, CCP, CDS, central counterparties, CFTC, Chevron Products Co. v. SemCrude L.P., Chicago mercantile exchange, Cleared Products, CME Clearport, CME Group, collateral, Collecting Futures Commission Merchant, commodity broker, Commodity Futures Trading Commission, covered swap entities, covered swap entity, credit default swap, cross-currency swaps, cross-margining, Dealer, debt obligation, Depositing Futures Commission Merchant, derivatives clearing organization, Dodd-Frank Act, eligible collateral, end-users, Farm Credit Administration, Farm Credit System, FCM, FDIC, Federal Agricultural Mortgage Corporation, Federal Deposit Insurance Corporation, Federal Home Loan Banks, Federal Home Loan Mortgage Corporation, Federal Housing Finance Agency, Federal National Mortgage Association, floors, futures, futures commission merchant, hedging, ICE Clear Credit, ICE Clear Europe, In re Lehman Brothers Holdings Inc et al, index CDS, inflation swaps, initial margin, insured obligation, LCH.Clearnet Ltd., liquidity, Major Security-Based Swap Participant, Major Swap Participant, mandatory clearing, margin, market liquidity, market participants, master netting agreements, New York Portfolio Clearing LLC, Office of the Comptroller of the Currency, options, Options Clearing Corporation, OTC derivatives, over-the-counter derivatives, portfolio margining, posted margin, prudential regulators, redundant margin, regulatory regime, risk, SEC, Securities and Exchange Commission, Security-Based Swap Dealer, security-based swaps, segmentation, swap dealer, swaps, swaptions, systemic risk, triangular setoff, uncleared swaps,

MFA Submits Comments on Hong Kong Consultation on Electronic Trading09.23.12


On September 23, MFA submitted comments to the Hong Kong Securities and Futures Commission on its consultation paper on the […]

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 SEC and CFTC on Definitions of “Swap Dealer, Security-Based Swap Dealer (together, SDs), Major Swap Participant, Major Security-Based Swap Participant (together MSPs) and Eligible Contract Participant (ECP)02.22.11


MFA submitted a comment letter to the SEC and CFTC on their joint proposed rule to further define swap dealer, […]

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Topics: abnormal price movement acknowledgment requirements, applicable MSP thresholds, asset mix, bank capital standards, capital markets, cash settled swaptions, CDS, CDS protection, central clearing, centrally cleared positions, CFTC, Chicago mercantile exchange, clearing member defaults, clearinghouse, CME, commercial hedging, commercial loans, Commodity Futures Trading Commission, counterparty domicile, counterparty exposure, credit default swaps, credit ratings, credit spreads, creditworthiness, currency based institutions, current uncollateralized outward exposure test, daily mark requirements, daily variation margin calls, daily volatility, Dealer, dealers, default risk, delta weighting, deregistration period, discount factor, ECP, eligible contract participant, end-users, feeder fund, financial counterparty, Financial Industry Regulatory Authority Inc., Financial Stability Oversight Council, FINRA, fixed downside risk, Form PF, Form PQR, FSOC, fund domicile, future exposure discount, hedge fund managers, hedge funds, high yield credit swaps, high-grade corporate securities, highly leveraged, highly liquid assets, independent amount of collateral, independent variable, index CDS, index derivatives, index reference entity, inflation, initial margin, interest rate swap, investment grade, investment-grade credit swaps, ISDA master agreements, jump-to-default risk, know your counterparty requirements, large private fund, liabilities to equity, LIBOR, limited purpose designations, liquidity, liquidity rights, longer-term leverage, Major Security-Based Swap Participant, Major Swap Participant, manager domicile, margin methodologies, mark-to-market exposure, market activity, market growth, market location, market-standard discount rate, master-feeder fund, minimum duration of status, mitigating commercial risk, msp, MSP definitions, MSP determination, MSP test, MSP thresholds, multiplier, non-ECP, non-investment grade, non-U.S. market, non-U.S. regulators., non-US domiciled fund, non-US entities, non-US securities, offshore fund, option expiration date, options on a swap, over-collateralization, overnight borrowing, physically settled swaptions, portfolio risk, potential future exposure calculation, potential future exposure test, potential systemic risk impact, Proposed Form PF section 1b, proposed form PF section 2(a), proposed form PF section 3, proposed form PF section 4, proposed Form PQR, quarters, question 11, question 27, question 38, question 47, question 5, question 68, reevaluation period, reference entity domicile, reproducible test, retail cash, Retail Forex Pool, risk factor multiplier, risk factor multipliers, risk mutualization, risk-mitigating tools, schedule B, SD, SD obligations, SEC, secured debt, Securities Exchange Commission, Security-Based Swap Dealer, security-based swaps, Senator Hagan, Senator Lincoln, short-term financing, short-term leverage, single-name CDS, smaller private fund, spread bank designation, substantial counterparty exposure, substantial position, swap rate, swap underlier, Swaps dealer, swaptions, systemic risk, systemically important, systemically important financial institution, term borrowings, threshold levels, tools of credit protection, trade verification, trading entity, traditional commodity pool, U.S. banking system, uncollateralized exposure, underlying instrument, undiversified market participant, United States financial markets, unpaid premiums, unsecured debt, upward adjustment, US entities, US Treasuries, valuation of collateral, variation margin, volatility,

MFA Comments to the “Over-the-Counter Derivatives Markets Act of 2009”11.09.09


MFA submitted a letter to the Department of the Treasury regarding the Obama administration’s legislative proposal titled the “Over-the-Counter Derivatives […]

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Topics: AAA credit rating AIG, airline, American International Group, Bankruptcy Code, bankruptcy-remote, capital formation, capital restrictions, cash-settled contracts, central clearing, central clearinghouse, CFTC, collateral segregation, commodity, Commodity Futures Trading Commission, credit risk, custodian, dealers, Department of the Treasury, derivatives clearing organizations, derivatives transactions, end-users, endowments, energy companies, Enron Corporation, exchange trading, exchange-traded products, Gary Gensler, hedge funds, hybrid market, initial margin, institutional investors, insurance companies, ISDA product definitions, LBIE, legacy standardized swaps, Lehman Brothers, local governmental entities, Long Term Capital Management, Major Swap Participant, market manipulation, non-clearable trade, non-cleared swap transactions, non-dealer entities, Obama Administration, OTC derivatives, OTC derivatives market, over-the-counter derivatives, Pension Funds, physically-delivered commodities, position limits, pre-merger notification regime, private funds, proprietary assets, registered derivatives clearing organization, regulatory framework, risk management, SEC, Securities and Exchange Commission, securities dealers, securities market, security-based swaps, segregation, substantial net position, substantial unsecured net position, swap dealers, swap market participant, thrift and insurance holding company, trade and position reporting, unsecured current credit exposure, utilities, variation margin,
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