MFA Comment Letters

Topic: flexibility

Comment Letter on Proposed Rule and Interpretation on Registration and Regulation of Security Based Swap Execution Facilities04.04.11


MFA submitted a comment letter to the SEC on its proposed rule and proposed interpretation on Registration and Regulation of […]

Supervisory Commitment Letter on OTC Derivatives Initiatives03.31.11


The MFA, along with several other major financial institutions, submitted this letter to William C. Dudley of the Federal Reserve […]

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Topics: 2011 EDDs ACP, affirmation, aggregate compression yields, Alliance Bernstein, Allocations, amortizing swaps, Anglo Irish Bank Corporation Limited, Asset Management Group of the Securities Industry and Financial Markets Association, automated processing, automatic compression, Autorite de Control Prudential, Bank of America-Merrill Lynch, Bank of England, Barclays Capital, baseline metrics, bilateral risk management, Blackrock Inc, Blue Mountain Capital Management LLC, BNP Paribas, buy-side institutions, caps, Cash Flow Matching for Equity Derivative Transactions, CCP, CDD, CDS, CDS central counterparties, CDX Untranched Swaption transactions, central clearing, CFTC, CIG, Citadel LLC, Citi, clearing agreement, client collateral, client data confidentiality, client onboarding, CLS, CLS Aggregation Service, CMD, collateral disputes, column-wise functional area, Committee on Payment and Settlement Systems, Commodities Major Dealers, Commodities Steering Committee, commodity derivatives, Commodity Futures Trading Commission, Complex Exotic Instruments, compression MIS, compression requirements, Connecticut Banking Department, Continuous Linked Settlement system, copper records, Core FX, Core FX settlement processing, COSC, cost-recovery, CPSS-IOSCO, credit, credit default swap, Credit Derivative Tranche Transactions, Credit Derivatives 2010 Documentation Update Working Group, Credit Implementation Group, Credit Suisse, Cross-Currency Guide, cross-currency swaps, currently eligible transactions, CZK, D.E. Shaw & Co L.P., data reporting, DC, dealer to dealer clearing, derivatives, Deutche Bank AG, direct buy-side clearing models, dispute reporting, Dispute Resolution, dispute resolution procedures, disputed margin calls, DTCC, DW Investment Management LP, DWG, EDC, EDRR, EFET, electronic messaging, electronically eligible conformations, EMEA EM Interdealer Options, EMIR legislation, end user clearing, enhanced clearing penetration, enhanced financial safeguards, equity, equity derivative, Equity Derivative Reporting Repository, Equity Derivatives Definitions, Equity Determinations Committee, Equity Steering Committee, ESC, European Central Bank, European Commission, European Interdealer Fair Value Swap, European Interdealer Index Swap, European MBS, European Securities Markets Authority, European swaptions, extending operating hours, Federal Deposit Insurance Corporation, Federal Reserve Bank of New York, Federal Reserve Bank of Richmond, Federal Reserve System, Financial Markets lawyers Group, Financial Stability Board, Fixed Recovery Swaps, flexibility, floors, flow/activity data, FMLG, foreign exchange derivatives, Foreign Exchange/Currency Derivatives Major Dealers, FpML Standards Committee, FRAs, functionality, FX derivatives, FX Novation Protocol, FX Volatility Swap, FXMD, G-14, G20, German Federal Financial Supervisory Authority, Global Compression, global derivatives, Goldman, Goldman Sachs Asset Management L.P., granularity, HSBC Group, HUF, ICE Clear Europe, ICE Trust, IETA, IGC Data Working Group, indirect buy-side clearing models, inflation swaps, infrastructure providers, inter alia, Interest Rate Derivative, interest rate derivatives, Interest Rate Derivatives Trade Reporting Repository, interest rates, international data standards, International Organization of Securities Commissions, international regulatory coordination, International Swaps and Derivatives Association Inc, Interoperability, IOSCO, IRRR, ISDA, ISDA 2011 convention on Portfolio Reconciliation and the Investigation of Disputed Margin Calls, ISDA 2011 Formal Market Polling Procedure, ISDA Credit Derivatives Determinations Committees, ISDA Credit Derivatives Physical Settlement Matrix, ISDA Minimum Market Standards for Portfolio Reconciliation, iTraxx Europe Untranched Swaption transactions, J.P. Morgan, Japan Financial Services Agency, LCH.Swapclear, LEAP, legal entity identifiers, LEI, lifecycle events, liquidity, LMBA, Managed Funds Association, margin requirement, market participants, market regulation, market structure, MarkitSERV, MarkitWire, Master Confirmation Agreements, matching and confirmation, Matrix Working Group, MCA, middleware platforms, Morgan Stanley, NDFs, NDOs, New "Gold" Products, New York State Banking Department, novation consent, Novation Consent Platform, ODRF, ODSG, Office of the Comptroller of the Currency, offsetting CDS hedge, operation efficiency targets, operational performance targets, OTC, OTC Derivatives Regulatory Forum, OTC derivatives risk management, OTC Derivatives Supervisors Group, Over-the-Counter, Pacific Investment Management Company LLC, Phase II Repository Reporting Expectations, platform convergence, portfolio compression, portfolio reconciliation, product pipeline, prudential regulator, quantitative stock, Rates TRR aggregate reporting, recovery lock transactions, regular compression cycles, reporting, Request for Proposal, residual risk position, Restructuring Credit Event, RFP, risk issues, Sachs & Co, SEC, Securities and Exchange Commission, SGD, signatories, Simple Exotic Options, Simple instruments, single currency basis swaps, Small Bang Protocol, Societe Generale, sovereigns, standardization, standardization benchmarking, standardization matrix, standardization narrative, standardized representation, statutory clearing requirements, steady state, submission targets, Sukuk Corporate, Swaptions on Indices, Swiss Financial Market Supervisory Authority, tear-up algorithms, The Royal Bank of Scotland Group, tradable instruments, Trade Affirmation, trade date repositories, Trade Date submission, Trade Information Warehouse, trade lifecycle event processing, trade pairing process, trade repositories, trade repository infrastructure, transaction level data submissions, Transaction Supplement, transparency, trickle down effect, UBS AG, uncleared transactions, uncollateralized payable, unique product identifiers, United Kingdom Financial Services Authority, Vanilla Options, Warehouse Trust, Wellington Management Company LLP, Wells Fargo Bank N.A., zero coupon swaps,

Comment Letter to the CFTC on its Proposed Core Principles and Other Requirements for Swap Execution Facilities03.08.11


MFA submitted a comment letter to the CFTC on its proposed Core Principles and Other Requirements for Swap Execution Facilities. […]

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Topics: annual review auction-based methods, available for trading, bilateral trading, bilateral trading environment, block size, block trade thresholds, block trades, cash position, CBOE futures exchange, CEA, central limit order variants, CFTC, chief compliance officer, cleared swaps, Commodity Futures Trading Commission, competition, complete audit trail, conflicts of interest, congestion, connectivity, credit default swaps, crossing, daily trading records requirements, data analysis, DCM, dealer-to-customer platforms, debt instrument, Designated Contract Market, discreet contract, electronic platform, emergency procedure, exchanges, exchanges for physical, exchanges for swaps, execution protocol, fixing, flexibility, futures position, grace period, grandfather relief, institutional investors, interstate commerce, ISDA, joint the trade, large notional transaction size threshold, limit order, linked transactions, liquidity, liquidity characteristics, major swap participants, Mandatory Execution Requirement, mandatory minimum required recipients, mandatory objective criteria, mandatory transparent criteria, Manipulation, market efficiencies, market liquidity, market-based competition, matching, matching traders, minimum block sizes, minimum block threshold, multiple-to-multiple trading venues, non-continuous liquidity, off-market transactions, one-to-one voice services, open outcry trading pits, order book, order book systems, OTC, OTC market, Over-the-Counter, Over-the-Counter Derivatives Markets, packaged transactions, permitted transactions, physical contract, physical position, price distortion, public information, quote requesters, quote-requesting participant, real-time public reporting of swap transaction data, recordkeeping requirements, regulatory efficiencies, reporting requirements, request for quote, required transactions, responsive quote, resting bids, RFQ, RFQ response period, RFQ system, Rulebook, SB SEF, security-based swap execution facility, SEF trading platforms, SEFs, SIFMA, single joint transactions, sporadic liquidity, swap data repositories, swap execution, swap execution facilities, timing delay, trading venues, transparency, voice-based system, voice-based trading, widened bid/offer spreads,

MFA Submits Letter to Department fo the Treasury Regarding Review by the Treasury Department of the Regulatory Structure Associated with Financial Institutions11.21.07


MFA submits letter to the U.S. Department of the Treasury in response to its request for recommendations on how to […]

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Topics: adequate disclosure Asian Countries, Australia, BaFin, bonds, business models, capital raising process, CFTC, collateral management stystems, collective investment vehicles, commercial, Commodity Futures Trading Commission, commodity pool operator, commodity pool operators, common stock, competitiveness concerns, compliance, conduct-of-business, conflicting regulatory edicts, Congress, costs, counterparites, cross-recognition efficiencies, crude oil, currency options template, customer protections, Department of the Treasury, derivatives, derivatives clearing organizations, Disclosure, duplicative systems, Europe, exchange, exchanges, fair prices, Federal Energy Regulatory Commission, federal government, FERC, Financial Industry Regulatory Authority, financial institutions, financial integrity systems, financial products, Financial Services Action Plan, Financial Services Roundtable, FINRA, flexibility, foreign markets, Fraud, fund of funds, funds, futures, futures brokerage commission payments, futures contracts, futures exchange, G-8 finance ministers and deputies, global alternative investment industry, gold, hedge fund investors, hedge funds, hedging, Henry Paulson, higher prices, intemediary brokerage firms, intermediaries, International Organization of Securities Commissions (IOSCO), international organizations, international portfolio valuation principles, international regulatory standards, Investor Protection, Japan's Financial Services Agency, liquid trading markets, local law enforcement, managed futures funds, margin area, margin levels, market and financial integrity, Market Particpants, market price transparency, marketplace, mutual, National Futures Association, natural gas, natural gas futures price manipulation, net capital, net long, Netherlands, NFA, optimal regulatory structure, options contracts, options trading, ownership interest, peer-to-peer guidance for hedge fund managers, Policy Makers, pool offerings, portfolio margining, Portfolios, President's Working Group on Financial Markets, principles-based approach, private pools of capital, private sector self-regulation, private transactions, prudential safety, public interest, public interest goals, public managed futures fund offerings, PWG, regions, regulation of intermediaries, regulatory framework, regulatory oversight, Regulatory Structure, retail customers, retail foreign exchange (FX), risk management, risk-based performance bond system, rules-based approach, safe harbor, SEC, securities, Securities and Exchange Commission, security futures, short, Sound Practices for Hedge Fund Managers, soundness regulation, state regulators, state securities regulators, statutory core principles, stock index, stock price, stock world, substantial inefficiency, tired system of regulation, trading business activties, trading platforms, transactions, twin peaks model, U.S. capital market competitiveness, underlying asset, uniform set of basic principles of regulation, United Kingdom's Financial Services Authority (FSA), United States, unwarranted costs, valuation, wheat, wholesale,

MFA Comments to SEC Regarding Proposals to Revise Limited Offering Exemptions in Regulation D10.19.07


MFA submits a comment letter to the SEC regarding their proposals to revise the limited offering exemptions in Regulation D.

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Topics: 20% beneficial owner Accerdited Investor, accounting officers, accredited investor, accredited natural person, affiliated issuer, attorneys, bad actor disqualification provisions, beneficiaries, blue sky filing, brokers, capital, capital formation, cease and desist, committed capital, compliance, deferred compensation, director, Disqualification Provisions, Division of Enforcement, dollar-amount thresholds, dollar-amount threshols, due diligence, economic efficiency, equity owners, executive officer, federal regulations, financial eligibility standard, financial sophistication standards, flexibility, Form D, Fraud, fund principals, Future Inflation Adjustment, General Advertising, general partner, General Solicitation, global alternative investment industry, grandfather provision, Grandfathered, hedge funds, higher dollar-amount thresholds, implications of the growth of hedge funds, inflation, inflation adjustments, Interation Safe Harbor, investments tests, investor, Investor Protection, Investor relations professionals, Issuer, issuers, joint income thresholds, Joint Investments, knowledgeable employees, limited announcement, Limited Coffering Exemptions, managed futures funds, managing member, Manner of Offering, marital assets, natural persons, net worth, offering, Offerings, offers, Office of Economic Analysis, operational, policymaker, pooled investment fund, pooled investment funds, pooled investment vehicles, predecessor, primary beneficiary, private placement, private placement offerings, Private Pooled Investment Vehicle Release, privated pools of captial, promoter, Public Offerings, qualification, qualified client, Qualified Client Definition, qualified purchaser, Qualified Purchaser Definition, qualifies purchasers, recdivism, research analysts, retention tool, risk, risk/return, sale limitations, SEC, securities, Securities and Exchange Commission, senior financial, Sophisticated Investor Standards, sophisticated investors, sotck, start up company, subscription agent, Subscription Agreement, threshold, traders, traders of a fund affiliate, transaction costs, transactions, transparency, Trust Grantors, Trustees, U.S. Congress, United States,
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