MFA Comment Letters

Topic: federal register

MFA Submits Letter to SEC on Proposed Capital, Margin, and Segregation Rules02.22.13


MFA submitted a comment letter to the Securities and Exchange Commission (SEC) on its proposed rules on “Capital, Margin, and […]

Click to expand relevant topics

Topics: "too big to fail \, 111th Congress, accounting, AIG, American International Group, asset class, asymmetrical initial margin exchange, asymmetry, bankruptcy, bankruptcy estate, Bart Chilton, Basel Committee on Banking Supervision, Ben Bernanke, best practices, bilateral exchange of variation margin, Broker, broker-dealer, buy-side firms, capital, capital charge, capital formation, capital inefficiency, capital requirements, Cash Flow, CCP, CDS, central clearing, central counterparty, CFTC, Chicago Mercantile Exchange Holdings Inc., Chicago Trading Company, collateral, collateral management, collateral management stystems, commodity broker, Commodity Futures Trading Commission, complexity, compliance, compliance date, Council of the European Union, counterparties, counterparty risk, credit default swap, credit risk, creditworthiness, cross-margining, cross-product master netting agreements, customer collateral, customer protection, customer replicability, customized risk management tools, Darrell Duffie, DCO, Dealer, dealers, default, default segregation model, derivatives, derivatives clearing organization, Division of Clearing and Intermediary Oversight, Dodd-Frank Act, efficiency, eligible collateral, endowments, enhanced protections, Eric Chern, European Commission, European Parliament, federal register, Federal Reserve Bank of New York, Federal Reserve Bank of New York Staff Report No. 424, Federal Reserve Board, fellow customer risk, financial contagion, financial crisis, Financial Industry Regulatory Authority, financial institutions, financial instrument, financial system, FINRA, forwards, Fraud, haircuts, hedge funds, House Committee on Financial Services, ICE Clear Europe Limited, ICI, independent third party custodian, Individual Segregation, initial margin, insolvency, international harmonization of regulations, International Organization of Securities Commissions, international regulatory standards, Investment Company Institute, investment risk, Investor Protection, IOSCO, ISDA, ISDA Margin Survey 2012, LCH.Clearnet Ltd., legal segregation with operation commingling, Lehman Brothers, leverage, liquidation, liquidation time horizon, liquidity, LSOC, Major Security-Based Swap Participant, Major Swap Participant, mandatory clearing, margin, margin requirements, margining, market participants, market practice, market risk, MF Global Inc., money market instruments, multiplier, netting, New York Portfolio Clearing LLC, non-commercial end-users, Notice of Exclusive Control, omnibus segregation, operational and legal commingling, operational costs, operational risk, Options Clearing Corporation, OTC derivatives, out-of-the-money, pension, Peregrine Financial Group, portability, portfolio compression, portfolio margining, portfolio reconciliation, Private Funds Managers, pro-cyclical effects, product type, proprietary information, prudential regulators, reconciliation, reform, registered clearing agencies, regulation, regulatory arbitrage, repurchase agreements, risk, risk management, Robert Wasserman, Russell Wasendorf, SEC, securities, Securities and Exchange Commission, Securities Industry and Financial Markets Association, Security-Based Swap Dealer, Security-Based Swap Transactions, security-based swaps, segregation, segregation model, sell-side firms, settlement, settlement risk, SIFMA, state and federal laws, state bank regulator, swap dealer, swap dealers, Swap Trading Relationship Documentation, systemic risk, tentative net capital, third-party custody arrangement, too interconnected to fail, trade repositories, trading costs, transparency, tri-party custodial arrangements, two-way margining, U.S. dollar, university endowment, Value at Risk, VaR, variation margin, White Paper, Working Group on Margining Requirements,

MFA Submits Letter to SEC on Sequencing Roadmap for Final Title VII Rules08.13.12


MFA submitted a comment letter to the SEC in response to its Sequencing Roadmap Policy Statement on the compliance dates […]

MFA Submits Comment Letter to CFTC on Proposed Dodd-Frank Implementation Rules for Mandatory Swap Clearing, Trade Execution, and Margin Rules11.04.11


The OTC derivatives reforms (Title VII) resulting from the Dodd-Frank Act will cause sweeping transformation of the OTC derivatives markets […]

Click to expand relevant topics

Topics: active fund bilateral execution, broad-based index credit default swaps, buy-side market participants, buy-side participants, Category 1 Entities, Category 2 Entities, Category 3 Entities, Category 4 Entities, CCP, central clearing, central counterparties, CFTC, class of swaps, clearing, clearing mandate, collateral, Commodity Futures Trading Commission, commodity swaps, compliance date, compliance schedules, cost-benefit analysis, counterparties, DCMs, derivatives clearing organization, Designated Contracts Markets, Dodd-Frank Act, electronic platform, end-user exemptions, exchanges, execution, execution venue, FCM, federal register, full-scale clearing, futures commission merchants, G20, Gary Gensler, interest rate swaps, liquidity, listing, made available for trading, Major Security-Based Swap Participant, Major Swap Participant, mandatory clearing, margining, margining requirements, market participants, netting, non-dealer market participants, non-MSP counterparties, novations, OTC derivatives, over-the-counter derivatives, partial tear-ups, phased implementation, price distortion, private funds, product definition rules, prudential regulators, real-time clearing, real-time reporting, Regulators, Rulemaking, Scott O'Malia, SEC, Securities and Exchange Commission, Security-Based Swap Dealer, security-based swap SEF, security-based swaps, SEF, swap data, swap dealer, swap execution facilities, swap transaction, swap transaction compliance, swaps, systemic risk, third-party subaccount, trade execution, trading documentation, transparency, uncleared swaps, variation margin, voluntary clearing,

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. […]

Click to expand relevant topics

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,

MFA Letter to FTC on Prohibition of Energy Market Manipulation Rule05.20.09


MFA jointly with FIA, CME Group, ICE and NFA submitted a letter to the Federal Trade Commission regarding its “Prohibition […]

Click to expand relevant topics

Topics: 1145 (7th Cir. 1982) 2002 WL 32135703, 2006 WL 778640 (S.D. Tex. March 24 2006), 250 N.W.2d 583 (Minn. 1976), 276 F.3d 583 (D.C. Cir. 2001), 276 F.3d at 591, 276 F.3d at 592, 420 F Supp.2d 1043 (N.D. Cal. 2006), 512 U.S. 594, 531 S.W.2d 805 (Tex. 1975), 537 U.S. 820, 546 F.2d 1361, 556 S.W.2d 420 (Ark. 1977), 677 F.2d 1137 (7th Cir. 1982), 706 (2d Cir. 1987), 823 F.2d 702, 883 F.2d 537 (7th Cir. 1989), accounts, Advanced Notice of Proposed Rulemaking, agents, agricultural feed-stocks, Agriculture Department, Amaranth, anti-manipulation protections, anti-manipulation system, Board of Trade of City of Chicago v. SEC, Board of Trade of City of Chicago v. SEC 677 F.2d 1137, Board of Trade of the City of Chicago, brokers, CBOT, CEA, CFTC, chain of precedent, Chciago Mercantile Exchange Inc., Chicago Mercantile Exch. v. SEC, Clayton Brokerage Co. v. Mouer, CME Group Inc., COMEX, commercial market, commodities, Commodity Exchange, Commodity Futures Trade Commission, commodity pool operators, commodity prices, commodity trading advisors, compliance burden, congressional grant, contract markets, contractual privity, contradictory requirements, corn, corporate disclosures, counterparties, crude oil, customer protection, DOE, Donald S. Clark, emissions credit, Energy Department, energy futures, energy markets, Environmental Protection Agency, EPA, ethanol, exclusive jurisdiction provision, exclusive jurisidiction provision, exclusive regulatory authority, false reports, Federal Energy Regulatory Commission, federal register, Federal Trade Commission, FERC, FIA, forward market business activities, fraud proscriptions, FTC, FTC v. Roberts, futures exchange, futures group, Futures Industry Association, gasoline, ICE, ICE Futures Canada, ICE Futures of Europe, ICE Futures U.S., Inc., instruments, IntercontinentalExchange, intermediaries, International Trading Ltd. v. Bell, Jeffrey Sprecher, Jerrold E. Salzman, John M. Damgard, Ken Roberts Co. v. FTC, limited-purpose national securities association, Manipulation, Market Manipulation Rulemaking, merchants, Minnesota v. Coin Wholesalers, National Futures Association, New York Board of Trade, new York Mercantile Exchange Inc., NFA, No. 01-1772, non-futures, non-petroleum based commodities, NYMEX, options trading, over-the-counter energy trading platform, Part 317, petroleum distillates, price artificiality, price discovery, price effects requirements, registered account executives, regulatory, resource limitations, safe harbor, SEC v. American Commodity Exch., SEC vs. Hopper, speculative limits, statutory authority, sugar, Thomas W. Sexton, Trichilo v. Sec'y of Health & Human Servs., U.S. Court of Appeals for the Seventh Circuit, United States Congress, US vs. Reliant Energy Services, USDA, wholesale markets, wholesale purchase, Williamson v. United States, Winnipeg Commodity Exchange,

MFA Letter to IRS Regarding Compliance Issues for Private Investment Funds Filing a Foreign Bank and Financial Accounts Report05.13.09


MFA submitted a letter as a follow up to its meeting on April 7 with officials from the IRS to […]

Click to expand relevant topics

Topics: adverse guidance AML program rule, banks, Betty Santangelo, board directors, bonds, brokerate accounts, Carl E. Kennedy, checking, commodity pool operators, commodity trading advisors, compliance, control the disposition, cost-efficient, covered financial accounts, demand, deposit, derivatives, Detroit Computing Center of the Internal Revenue Service, domestic feeder fund, domestic limited liability companies, domestic limited partnerships, Don Carbaugh, Don Moorehead, equity interest, FBAR, FBAR Requirements, federal register, federal tax return, filing exception, Financial Crimes Enforcement Network, FinCEN, flow through, Foreign Bank and Financial Accounts Reports, foreign currencies, foreign securities, Form 1040, Form 1065, Form 1120, Form 5500, Form 990, Form 990-PF, Form TD 90-22.1, Form TD F 90-22, Form TDF 90-22.1, Fund Managers, general definitions, Glen Kirkland, group filings, hedge funds, illiquid, Internal Revenue Service, interpretive guidance, IRS, IRS Reports Clearance Officer, John G. Gaine, legislators, limited liability companies, lock-up periods, master-feeder structures, mutual fund, Nancy Rose, notes, Office of Chief Counsel, OMB No. 1545-2038, Partnerships, Patton Boggs LLP, pooled interest, President's Working Group on Financial Markets, prior submissions, private equity, private investment funds, publicly-traded corporations, PWG, Question 7a, Question 9, Questioon 6a, regulations, savings, schedule B, Schedule N, Schulte Roth & Zabel LLP, Side-by-Side Structure, signature authority, SRZ, stock certificates, tax forms, tax-exempt organization, taxpayer identification number, U.S. tax-exempt investors, United States Department of the Treasury, William Langford,

MFA Comments to CFTC on Proposed Rulemaking on Significant Price Discovery Contracts on Exempt Commercial Markets02.10.09


MFA submitted comments to the CFTC regarding its proposed rulemaking on significant price discovery contracts on exempt commercial markets.  MFA […]

MFA Comments to SEC on FINRA Regulation of Compensation, Fees and Expenses in Public Offerings of Real Estate Investment Trusts and Direct Participation Programs06.04.08


MFA submitted a comment letter to the SEC on FINRA’s rule 2810 with respect to trail commissions along with the […]

Results 1 - 10 of 10