harmonization Archives - Managed Funds Association

Joint Letter on SEC Concept Release09.24.19

On September 24, MFA submitted a joint letter with AIMA in response to the SEC’s Concept Release on Harmonization of […]

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Topics: harmonization SEC, SEC concept Release, investment adviser,

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14

MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: CFTC Commodity Futures Trading Commission, Timothy Massad, Mark Wetjen, Scott O'Malia, Sharon Bowen, J. Christopher Giancarlo, swaps, commodity pool operators, CPO, commodity trading advisors, CTA, alternative investment strategies, Dodd-Frank Act, OTC derivatives, systemic risk, transparency, central clearing, swap execution facilities, SEF, designated contract markets, DCM, regulation, package transactions, market infrastructures, recordkeeping requirements, swap data reporting, Cross-Border, central counterparties, CCP, third country, regulatory requirements, alternative investment funds, EMIR, JOBS Act, private investment vehicles, regulatory framework, hedge fund, fund of funds, private equity fund, real estate investment trust, burdensome, CPO delegation, temporary interim relief, private funds, harmonization, no-action relief, SEC, Securities and Exchange Commission, Policy Makers, customer protection, U.S. Congress, Bankruptcy Code, futures commission merchant, FCM, legal segregation with operation commingling, LSOC, market participant, MF Global Inc., Peregrine Financial Group, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, segregated account, FCM counterparty, position limits, buy-side, straight-through processing, made available for trading, MAT, inter-dealer market, anonymity, execution, proprietary trading tools, dealer-to-customer platforms, liquidity, derivatives clearing organization, DCO, Dealer, interest rate markets, swap curves, swap butterflies, invoice spreads, swaptions, Vincent A. McGonagle, exchange for related position, EFRPs, benchmark contracts, SIFMA AMG, Asset Management Group of the Securities Industry and Financial Markets Association, Division of Swap Dealer and Intermediary Oversight, Division of Market Oversight, introducing broker, assets under management, AUM, trading privileges, commodity pool, floor brokers, Alternative Investment Management Association, AIMA, swap data repository, SDR, Commodity Markets Council, alpha swap, beta swap, gamma swap, Major Swap Participant, MSPs, European Union, EU, bespoke swaps, International Swaps and Derivatives Association, ISDA, master agreement, European Commission, OTC Derivatives Regulators Group, mandatory clearing, United States, Cayman Islands, U.S. person, swap dealer, financial counterparty, commodity interests, privately offered commodity pools, Cayman Islands Monetary Authority, British Virgin Islands Financial Services Commission, Financial Conduct Authority, Hong Kong, Securities and Futures Commission, private investment funds, limited partnership, general partner, corporations, Trust, limited liability companies, public investment fund, board of directors, chilling effect, NFA, National Futures Association, due diligence, compliance, registered investment adviser, President Obama, Obama Administration, U.S. Department of the Treasury, quarterly account statements, service providers, illiquid assets, Form PF, Form CPO-PQR, Form CTA-PR, custody rules, generally accepted accounting principles, GAAP, Form PQR, haircuts, Committee of Payment and Settlement Systems, International Organization of Securities Commissions, IOSCO, Financial Stability Board, FSB, risk management, initial margin, variation margin, loss allocation, Full Physical Segregation, customer collateral, collateral, insolvency, cleared swaps, hedgers, short, price discovery, spot-month position limits, physically settled, cash-settled contracts, natural gas, gold, silver, owned entities, passive ownership, exemptive relief, speculation, aggregation,

MFA Files Petition for Rulemaking to Amend Certain CPO/CTA Recordkeeping Requirements07.21.14

MFA, jointly with the Investment Adviser Association and the Alternative Investment Management Association, submitted a petition to the Commission to […]

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Topics: IAA AIMA, Investment Adviser Association, Alternative Investment Management Association, CFTC, Commodity Futures Trading Commission, recordkeeping, adviser registration, recordkeeping requirements, commodity pool operator, CPO, commodity trading advisor, CTA, permissible entity, no-action relief, Petition for Rulemaking, investment management industry, pooled investment vehicles, separate account structure, investment adviser, commodity, burdensome, electronic recordkeeping regulations, Investment Company Institute, ICI, National Futures Association, NFA, SEC, Securities and Exchange Commission, examination, broker-dealer, futures commission merchant, FCM, introducing broker, forwards, forward transactions, Word Perfect, harmonize compliance obligations, registered investment companies, brokerage, custodian, Transfer Agent, harmonization, U.S. Department of Justice, third-party recordkeeper, compliance burden,

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

MFA and AIMA Submit Comments to CFTC on Swap Data Reporting Rules05.27.14

MFA and AIMA submitted a joint comment letter to the CFTC on its swap data reporting rules. In the letter, […]

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Topics: CFTC Commodity Futures Trading Commission, AIMA, swap data repository, SDR, recordkeeping, reporting requirements, harmonization, swaps, swap transaction, confirmation data, valuation, valuation data, derivatives clearing organization, DCO, adviser registration, registered swap dealer, bespoke swaps, package transactions, collateral, alpha swap, Emerging Markets Association, ISDA, ISDA master agreement, International Swaps and Derivatives Association, swap dealer, counterparties, FpML Standards Committee, FIXML, European Union, EU, intention to be cleared, ITBC swap, beta swap, gamma swap, Swap Execution Facility, SEF, Designated Contract Market, DCM, straight-through processing,

MFA Submits Letter to European Commission on FX Spot Transactions05.09.14

MFA filed comments with the European Commission (“Commission”) in response to its consultation paper on FX financial instruments. The consultation […]

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Topics: European Commission Richard H. Baker, FX swaps, market participants, EMIR, Cross-Border, counterparties, CFTC, Commodity Futures Trading Commission, MiFID II, harmonization, exchange trading, regulatory regime, settlement, T+2, settlement period, currency, Security-Based Swap, swaps, recordkeeping, derivative, forward, EU Member State, non-EU counterparties, European Union, EU, security, commodity, financial instrument, Administrative Burdens, foreign currency assets, CLS Bank International, payment-versus-payment, non-defaulting counterparty, netting, liquidity, operational efficiency, Committee on Payment and Settlement Services, CPSS, Basel Committee on Banking Supervision, customer protection, U.S. Department of the Treasury, central clearing, duplicative regulation, Bank for International Settlements, United Kingdom, Triennial Central Bank Survey, Dodd-Frank Act, mandatory clearing,

MFA Submits Comments in Response to SEC Proposed Amendments to Regulation D, Form D and Rule 15609.23.13

MFA submitted a letter to the Securities and Exchange Commission in response to proposed amendments to Regulation D, Form D […]

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Topics: Securities and Exchange Commission SEC, Regulation D, Form D, market practices, JOBS Act, General Solicitation, private placements, capital formation, Investor Protection, transparency, private fund, private capital markets, hedge funds, issuers, due diligence, John Thune, registered investment companies, RICs, private fund managers, examination process, Office of Compliance Inspections and Examinations, OCIE, hedge fund industry, assets under management, AUM, Form ADV, state securities regulators, Form PF, proprietary information, Rulemaking, adviser registration, Norm Champ, Division of Investment Management, PLI Hedge Fund Management Conference, Advance Form D, cost-benefit analysis, compliance costs, registered investment adviser, hedge fund managers, compliance, public markets, Fund Sponsors, United States Congress, capital markets, Form 13F, Schedule 13D, censure, cease and desist, Verification Methods, accredited investor, general solicitation materials, legends, disclosure requirements, anti-fraud rules, performance, sophisticated investors, high net worth requirements, institutional investor, private fund offerings, retail investors, private placement memorandum, Ban on General Solicitation and Advertising, accredited investors, efficiency, competition, pitch book, marketing materials, beneficial owners, equity, natural persons, eligible purchasers, general partner, Federal Securities Laws, deemed compliant, Pacific Mutual Life Insurance Company, Variable Life, Franklin Group of Funds, investment company, statement of policy, mutual fund, interpretive guidance, commodities, derivatives, liquidity, qualified purchasers, qualified clients, Global Investment Performance Standards, investor qualification standards, knowledgeable employees, harmonization, Elizabeth Murphy, Commodity Futures Trading Commission, CFTC, pool participants, Ray Garrett, Colorado Bar Association,

MFA and AIMA Submit Letter to ESMA on Contracts Having a Direct, Substantial and Foreseeable Effect within the EU09.16.13

MFA and the Alternative Investment Management Association (AIMA) submitted a letter to the European Securities and Markets Authority (ESMA) in […]

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Topics: ESMA AIMA, European Securities and Markets Authority, Alternative Investment Management Association, EMIR, European Market Infrastructure Regulation, third country, duplicative regulation, derivatives transactions, derivatives contracts, European Union, EU, European Commission, counterparties, Commodity Futures Trading Commission, CFTC, Securities and Exchange Commission, SEC, Alternative Investment Fund, investment manager, swaps, U.S. person, security-based swaps, mandatory reporting, substituted compliance, Cross-Border, due diligence, credit derivatives, insurance contracts, market participants, OTC derivatives, direct substantial and foreseeable effect, currencies, harmonization,

MFA and AIMA Submit Letter to SEC on Proposed Cross-Border Rules for Security-Based Swaps08.19.13

The Managed Funds Association (MFA) and the Alternative Investment Management Association (AIMA) submitted a letter to the Securities and Exchange […]

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Topics: Securities and Exchange Commission SEC, AIMA, Alternative Investment Management Association, swaps, Cross-Border, security-based swaps, registration, adviser registration, Security-Based Swap Dealer, Major Security-Based Swap Participant, Dodd-Frank Act, market participants, prudential regulators, transaction-level requirements, private fund, Counterparty, U.S. person, international regulatory coordination, harmonization, regulatory regimes, segregation, reporting, clearing, execution, Issuer, investment company, partnership, Corporation, Trust, derivatives markets, Commodity Futures Trading Commission, CFTC, interpretive guidance, extraterritoriality, substituted compliance, duplicative regulation, European Securities and Markets Authority, ESMA, EMIR, de minimis threshold, mandatory clearing, London, derivatives, OTC derivatives, European Commission, central counterparty, trade repositories, European Union, EU, MiFID, MiFIR, MiFID II, Council of the European Union, European Parliament,

MFA Submits Letter to SEC Staff Explaining CFTC’s LSOC Model Related to SEC Proposed Segregation Rules06.25.13

MFA submitted a letter to staff from the Division of Trading and Markets of the Securities and Exchange Commission (SEC) […]

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Topics: Securities and Exchange Commission SEC, LSOC, legal segregation with operation commingling, Commodity Futures Trading Commission, CFTC, segregation, cleared swaps, collateral, commodity broker, bankruptcy, harmonization, security-based swaps, omnibus segregation, Security-Based Swap Dealer, Major Security-Based Swap Participant, fellow customer risk, capital requirements, swap dealer, Major Swap Participant, major security-based swap dealer, derivatives clearing organization, DCO, futures commission merchant, FCM, cleared swaps customer accounts, permitted depository, Chapter 7 of the Bankruptcy Code, risk management, default, double default, trustee, operational costs, clearinghouse, MF Global Inc., Peregrine Financial Group,

MFA Comment Letters

Topic: harmonization