MFA Comment Letters

Topic: FDIC

MFA Comment Letter to Prudential Regulators on Final Margin Requirements11.25.14


On November 24, MFA submitted a comment letter to the U.S. Prudential Regulators (Fed, FDIC, OCC, FCA and FHFA) to […]

MFA Submits Letter and White Paper on Protection of Non-Public, Sensitive, and Proprietary Information by FSOC Members05.22.13


MFA submitted a cover letter and white paper to each member of the Financial Stability Oversight Council (FSOC) on the […]

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Topics: Adam Clark-Joseph adviser registration, Andrei Kirilenko, Board of Governors of the Federal Reserve System, broker-dealer, CFTC, CIGFO, clearinghouses, Commodity Futures Trading Commission, commodity pool operator, commodity trading advisor, confidentiality, Consumer Financial Protection Bureau, Council of Inspectors General on Financial Oversight, CPO, CTA, data collection, data repositories, DCO, Department of the Treasury, Designated Clearing Organizations, Dodd-Frank Act, FCM, FDIC, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Federal Insurance Office, financial stability, Financial Stability Oversight Council, Form CPO-PQR, Form CTA-PR, Form PF, front running, FSOC, futures commission merchants, harmonization, high frequency trading, information security program, inspector general reports, intermediary, investment advisers, Jaksa Cvitanic, legal entity identifiers, liquidation, Managed Funds Association, market participants, market structure, National Credit Union Administration, National Institute of Standards and Technology, NIST, Office of Financial Research, Office of the Comptroller of the Currency, President Obama, registered investment adviser, reporting, research, Reverse Engineered, Richard A. Shilts, Richard H. Baker, Rulemaking, SBSDR, SDR, SEC, SEC Office of Inspector General, Securities and Exchange Commission, Security-Based Swap Data Repositories, self-regulatory organization, SRO, substituted compliance, swap data repository, systemic risk, Trade Secrets, trade sectrets, Trading Activities, U.S. House of Representatives Committee on Financial Services, U.S. securities law,

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 Amicus Brief on Issue of Creditor Coordination06.29.12


On June 29, MFA filed an amicus brief in the 11th Circuit en banc review of the CompuCredit case.  At […]

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Topics: Aidan Synnott Ali Stoeppelwerth, alternative investment industry, anticompetitive, Arizona v. Maricopa County Medical Society, Bankruptcy Code, Bankruptcy Filing, banks, bilateral monopoly, Board of Governors of the Federal Reserve System, Bondholder, bonds, borrowers, Brendy Kuehne, Broad. Music Inc. v. Columbia Broadcasting Sys. Inc, broker-dealer, Bus. Elecs. Corp. v. Sharp Elecs. Corp., capital, capital formation, chilling effect, Classic Cheesecake Co. Inc. v. JPMorgan Chase Bank NA, collective action risks, competition, Compucredit Holdings Corporation v. Akanthos Capital Management LLC, Conrad Duberstein, contract, contractual relationship, corporate bonds, credit market, credit squeeze, creditor, creditor coordination, Daniel Crane, debt instruments, debtor, distressed debt, Edward Altman, Falstaff Brewing Corp. v. New York Life Ins. Co., FDIC, Federal Deposit Insurance Corporation, Federal Trade Commission v. Brown Shoe Co., Federal Trade Commission v. Indiana Federation of Dentists, Federal Trade Commission v. Superior Court Trial Lawyers Association, Financial Crisis Inquiry Commission, Finnegan v. Campeau Corp., Glenn Merrick, hedge funds, high-velocity market, institutional lender, interest rates, investment banks, Ireland v. Craggs, John Coffee Jr., Judge Easterbrook, Leegin Creative Leather Products Inc. v. PSKS Inc., leverage, Loan Syndications and Trading Association, low-velocity market, Marcel Kahan, Maris Distrib. Co. v. Anheuser-Busch Inc., market power, maturity date, Michael MacKenzie, Moses Silverman, National Collegiate Athletic Association v. Board of Regents, New York University Salomon Center, Nicole Bullock, Northwest Wholesale Stationers Inc. v. Pacific Stationery & Printing Co., Office of the Comptroller of the Currency, Palmyra Park Hosp. Inc. v. Phoebe Putney Memorial Hospital, par value, per se rules, pre-packaged bankruptcy, price competition, price-fixing, primary market, Reisner v. General Motors Corp., Reiter v. Sonotone Corp., risk portfolio, secondary loan markets, securities firms, Securities Industry and Financial Markets Association, Shared National Credit Review, Sharon Steel Corp. v. Chase Manhattan Bank NA, SIFMA, Smith v. The Ferncliff, State Farm Mutual Auto. Ins. Co. v. Physicians Injury Care Center Inc., Stern School of Business, syndicated loan market, systemic risk, Tomotaka Fujita, Twin City Pipe Line Co. v. Harding Glass Co., U.S. Court of Appeals for the Eleventh Circuit, U.S. Court of Appeals for the Second Circuit, U.S. Court of Appeals for the Seventh Circuit, Unijax Inc. v. Champion International Inc., United Airlines Inc. v. U.S. Bank NA, United States v. Giordano, United States v. Topco Assocs Inc., Volt Info. Scis. Inc. v. Board of Trs. of Leland Stanford Jr. University, William Klein,

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

Comment Letters to Prudential Regulators on their Proposed Rules for Margin and Capital Requirements for Covered Swap Entities07.11.11


MFA submitted a comment letter to the Prudential Regulators in response to their notice of proposed rulemaking on Margin and […]

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Topics: "too big to fail adverse pricing, asset class, Ben S. Bernanke, bilateral exchange of variation margin, Board of Governors of the Federal Reserve System, call option, capital charge, Capital Relief for Cleared Swaps, central clearing, central clearinghouse, CFTC, cleared swap transactions, clearing eligible, Commodity Futures Trading Commission, commodity swaps, consistency, counterparties, counterparty risk, covered swap participants, credit default swap, cross-product netting agreements, CSEs, customized transactions, DCO, delivery of margin, derivatives clearing organizations, equity swaps, Eurodollar futures, Farm Credit Administration, FCM, FDIC, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, financial entity counterparties, five-day time horizon, funding costs, futures commission merchant, Gary Gensler, House Committee on Financial Services, illiquid security, indirect transmission, interest rate swap, interest rate swaps, liquidation value, liquidity, major swap participants, mandatory clearing requirements, minimize risk, multi-lateral netting agreements, non-cash collateral, non-cleared commodity options, Notice of Proposed Rulemaking on Margin and Capital Requirements for Covered Swap Entities, Office of the Comptroller of the Currency, operational costs, over-collateralization, paired products, pension plans, physically-settling forwards, proprietary models, referenced bond, repurchase agreements, risk management, risk reduction tool, risk-based margin requirements, robust netting arrangements, SDs, SEC, Securities and Exchange Commission, security lending agreements, security-based swaps, swap dealers, swap documents, swap markets, swap portfolio, systemic risk, ten-day liquidation time horizon, Timothy Geithner, total return swap, trading contracts, transparency, Treasury, uncleared swaps, uncollaterized swap positions, university endowments, unsecured counterparty credit risk, valuation formulas, variation margin,

Comment Letter in Response to the FDICs Interim Final Rule Implementing Certain Provisions of the Orderly Liquidation Authority (OLA),03.28.11


MFA filed a comment letter in response to the FDICs interim final rule implementing certain provisions of the orderly liquidation […]

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Topics: allocation of capital Bankruptcy Code, Board of Directors of FDIC, bond holders, bridge financial company, chapter 7 liquidation, claim disallowance, contingent claims, covered financial institution, creditor involvement, creditor losses, creditor participation, critical vendors, debt instrument, default, Disclosure, distress, doctrine of necessity, equality of distribution, estate, fair market value, favored creditors, FDIC, Federal Deposit Insurance Corporation, Federal Rules of Bankruptcy Procedure, financial market meltdown, insolvency laws, insolvency proceeding, investor, judicial review, Liquidation Authority provisions, liquidation framework, liquidation process, liquidation value, longer-term financing, market data, market discipline, market expertise, market fluctuations, moral hazard, non-statutory considerations, OLA, orderly liquid authority, preferred creditors, providers of lines of credit, publicly traded securities, quotes, ratable payments, receivership, receivership estate, repurchase agreements, secured creditor, securities contracts, shareholder losses, short-term creditors, short-term financing, short-term lenders, swaps, systemic risk, systemically significant firm, third-party market participants, transparency, true market valuation, underlying collateral, unduly delay, Union Bank v. Wolas, unsecured claim, unsecured creditors, unsecured deficiency claim, US government securities, valuation date, valuation of collateral, valuation rules, volatility,

Comment Letter Responding to FDIC’s Proposed Rules to Implement Certain Provisions of the Orderly Liquidation Authority in Title II of the Dodd-Frank Act.01.18.11


MFA filed a comment letter with the Federal Deposit Insurance Corporation (the FDIC) in response to the FDICs proposed rules […]

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