MFA Comment Letters

Topic: insurance companies

Comment Letter on IOSCO’s Consultation Report on ‘Regulatory Issues Raised by the Impact of Technological Changes on Market Integrity and Efficiency,’08.12.11


MFA submitted comments to IOSCO on its consultation report on Regulatory Issues Raised by the Impact of Technological Changes on […]

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Topics: 1963 Special Study 1963 Special Study of the Securities Markets, 2010, affirmative stock locate framework, AIG, algorithmic trading, algorithms, Arndt, Barclays Capital Equity Research, Barclays Plc., bid-ask spreads, broker dealers, buy-side brokers, CFTC, circuit breakers, co-location services, computer programs, connectivity, Consultation Report, dark pools, DEA, Division of Risk, Dow Jones Industrial Average, E-Trade, Economic Growth, educational campaigns, effective spreads in European equities, efficiency, electronic markets, Elizabeth Murphy, empirical data, endowments, erroneous trades, ETFs, EU, executing brokers, execution speed, Fannie Mae, fees, Fidelity, fiduciary obligation, Financial Crisis of 2008, fixed commission rates, flash crash, Flash Crash of May 6, foundations, France, Freddie Mac, Germany, Goldman Sachs, Gomber, HFT, high frequency trading, institutional investor, institutional investors, insurance companies, intermediary firm, International Organization of Securities Commissions, investment time horizons, Japan, Joint Advisory Committee on Emerging Regulatory Issues, Joint Industry Limit Up-Limit Down Proposal, LaBranche, limit-up/limit-down systems, long-term, low latency, Lutat, market access, Market Break of 1962, Market Crash of 1987, market depth, market dislocations, market efficiencies, market information, market liquidity, market trends, Merrill Lynch, monopolies, Mr. Werner Bijkerk, mutual funds, Nasdaq, National Securities Clearing Corporation, NBBO, New York Stock Exchange, NSCC, Office of Markets in the Division of Risk, order execution, order-to-trade ratios, OSCO, oversight, passive, pensions, Peter Gomber, pricing reliability, proprietary, proprietary trading tools, quote stuffing, Regulatory Issues Raised by the Impact of Technological Change on Market Integrity and Efficiency, Rosenblatt Securities, Schwab, SEC, Securities Exchange Commission, single-stock circuit breakers, Spain, sponsored access, spreads, standardize disclosure, Strategy and Financial Innovation, Strategy and Innovation memorandum, TABB Group, TAGG Group, TD Ameritrade, Technical Committee, Technical Committee of the International Organization of Securities Commissions, technological developments, third party vendors, Thomson, threshold securities, trading strategies, transaction delivery, transaction fees, transparency, two-sided displayed quotes, Uhle, UK, wait-and-see, Washington Mutual,

Comment Letter Responding to FSB’s Background Note, ‘Shadow Banking: Scoping the Issues’05.16.11


MFA submitted a comment letter in response to the FSBs Background Note on Shadow Banking. In our letter, we discussed […]

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Topics: ABCP conduits asset concentration, asset management structures, Background Note, bank holding companies, bank/broker counterparts, banks, borrowing arrangements, broker dealers, collateral, concentration of assets, counterparty risk management, Counterparty Risk Management Policy Group, credit intermediation chain, derivatives contracts, direct regulation of entities, Distribution/Wholesale Funding, Financial Stability Board, FSA, haircuts, hedge fund adviser, hedge fund borrowings, hedge fund industry, hedge fund leverage, highly leveraged financial institutions, individual adviser, initial margin, insurance companies, interconnectedness of hedge funds, investors, large corporate investors, legal separation of different funds, liquidity transformation, Long Term Capital Management, long-only mutual funds, low leverage, LTCM, macro-prudential approach, manage liquidity risk, margining process, mark-to market margining, maturity transformation, mutual funds, non-bank institutional investors, nonbank financial institutions, off-balance sheet vehicles, Pension Funds, private equity funds, regulation, regulatory arbitrage, regulatory arbitrage concerns, repo collateral, repo liabilities, repo sellers, secured basis, secured borrowings, shadow banking system, Shadow Banking: Scoping the Issues, short term liability, stable capital, systemic impact of hedge funds, systemic risk concerns, The UK Financial Services Authority, U.S. President's Working Group on Financial Markets, U.S. Securities and Exchange Commission,

Comment Letter to the CFTC on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants02.28.11


MFA submitted a comment letter to the CFTC on its proposal on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for […]

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Topics: banks best practices, bid spreads, bilateral portfolio compression exercise, bilateral portfolio reconciliation exercise, broader markets, calendar day, CFTC, clearance, clearing satisfying requirements, collateral management, collateral steering committee of the International Swaps and Derivatives Association Inc., Commodity Futures Trading Commission, complex swap, compliance period, confirmation, confirmation periods, confirmation requirement, consistent timing, Counterparty, counterparty risk, customized swaps, DCM, DCO, derivatives clearing organization, Designated Contract Market, dividend payment, dollar threshold, electronic matching platforms, electronic matching process, electronic processing, exchange execution, financial entities, financial entity, heavily negotiated swaps, hedging risk, insurance companies, ISDA, legal risks, life cycle events, limiting parties, liquidity, major swap participants, mandated timeframes, margin disputes, market disruption, market participants, market risk, market-driven solution, merger, modification, MSPs, multilateral compression, multilateral portfolio compression exercises, multilateral portfolio reconciliation exercise, nominal value, novation, offer spreads, operational abilities, operational risk, over-the-counter derivatives, partial termination, pension plans, portfolio compression requirements, portfolio compression rule, portfolio reconciliation, position level discrepancies, position level portfolio reconciliation, post-trade exercises, pre-trade draft acknowledgement requirement, private funds, rights, risk mitigation benefits, SDs, SEC, Securities and Exchange Commission, SEF, swap dealers, Swap Execution Facility, swap markets, swap portfolio trade confirmation, swaps portfolio, time-sensitive swaps, timing requirements, trade acknowledgment, trade capture system, trade execution, valuation data, valuation discrepancy, Valuation Disputes, volatility,

Comment Letter on Proposed Rulemaking for Systemically Significant Institutions02.25.11


MFA submitted a letter to the Financial Stability Oversight Council in response to the Councils proposed rule regarding the criteria […]

Letter to the European Commission in Response to its Consultation Paper, Review of the Markets in Financial Instruments Directive (MiFID)02.02.11


MFA submitted comments to the European Commission in response to its Consultation Paper, Review of the Markets in Financial Instruments […]

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Topics: "strict equivalence" regime accurate price discovery, actionable IOIs, affirmative and negative obligations, aggregate open interest/notional amount, AIFM directive, algorithmic trading, alternative investment fund managers, alternative trading systems, APAs, approved publication arrangements, arbitraging, article 4(8) of MiFID, Asian Markets, asset managers, ATSs, automated execution technology, automated trading, banks, block sized trades, Bloomberg L.P., broker dealers, broker-dealer capital, brokers, capital flows, capital formation, cash balance, CCP, CDS market, certificates, CESR, circuit breakers, client identifier, co-location facilities, commodity derivatives, commodity derivatives market, composite quotation system, comprehensive notional data, comprehensive price date, concentrated risk solution, confidentiality obligation, conflicts of interest, Congress, consolidated core data, Consolidated Tape, Consolidated Tape Association, consolidated transaction reporting system, consultation papers, contract, core date, cost-effective manner, cost/benefit analysis, CQ plan, credit default swaps, credit flows, daily trading volume threshold, dark pools, data consolidation, deep market, depositary receipts, depth of market quotations, depth-of-market fees, derivatives position, direct market access, Disclosure, due diligence obligations, electronic market-making, electronic trading platforms, EMIR, equity investors, equity markets, equivalence mechanism, ESMA, EU, European Commission, European Commission on Standardisation and Organised Platform Trading of OTC Derivatives, European Commission Request for Additional Information in relation to the Review of MiFID, European Commission's report of Sovereign CDS, European Consolidated Tape, European Market Infrastructure Regulation, European OTC derivatives markets, European Union, ex-ante disclosure, ex-post disclosure, exchange traded funds, exchange trading, exchange-traded products, financial institutions, financial regulatory system, Financial Stability Board, flash crash, fleeting arbitrage opportunities, G20, global connectivity infrastructure, Google, hard position limits, harmonised position information, hedge funds, hedgers, HFT, HFT trades, high frequency trading, horizon strategies, indications of interest, information requirements, insurance companies, inter-market arbitrage, International Swaps and Derivatives Association, inventory risk, investment strategies, investor confidence, Investor Protection, IOIs, ISDA, latency, lending flows, level playing field, limit down system, limit orders, limit up system, liquid derivatives, liquid market, liquidity, liquidity provision requirements, low latency technology, low latency technology chain, margin requirements, market connectivity intermediaries, market data, market disorder, market efficiency, market impact, market makers, market manipulation, market stability, market turmoil, market-wide single stock circuit breakers, Markets in Financial Instruments Directive, mechanical imposition, member states, MiFID, MiFID framework directive, minimum duration of orders, minimum quantitative threshold, minimum tick sizes, national best bid and offer, National Market System, NetCoalition, NetCoalition v. Securities and Exchange Commission, nexus, non-equity instruments, non-EU asset managers, non-EU investment firms, non-EU markets, non-hedging, non-HFT trade, non-retail clients, opaque market centers, order flow, order stubs, order-slicing methodologies, Organised Trading Venues, OTC, OTC contract, physical commodity markets, portfolio manager, position management, position-level data, post-trade reporting proposals, post-trade transparency, pre-trade checks, pre-trade transparency, pre-trade transparency waivers, price discovery, price movement, proprietary strategies, quotations, reasonable threshold, reduced transaction costs, regulatory "tax, regulatory authorities, regulatory framework, regulatory transparency thresholds, reporting obligations, reporting protocols, reporting regimes, retail client, risk capital, risk controls, risk exposure, risk management, risk warnings, safeguards, SEC, Securities and Exchange Commission, securities financing transaction, Securities Industry and Financial Markets Association, security-based derivatives, sharp shoot, short-term price swings, sovereign CDS, specified maximum execution speeds, speed bumps, stale orders, statutory obligation, strategy holding periods, strict equivalence, sufficiently liquid, summary disclosure, surveillance tools, systemic risk, systemic risk grounds, technological innovation, technology-driven market makers, third country firms, third country regime, third party information vendors, title transfer collateral arrangement, title transfer collateral arrangements, trade repository, trader ID, trading delays, transaction report, transparency directive, UCITS, UCITS Directive, UK Treasury and Financial Services Authority, ultra low-latency technology, unilateral bans, US markets, US Securities Industry Automation Corporation, volatility, waivers, Yahoo Inc,
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