MFA Comment Letters

Topic: interest rate derivatives

MFA Submits Letter to ESMA on Draft Technical Standards on OTC Derivatives08.05.12


MFA submitted a comment letter to the European Securities and Markets Authority (“ESMA”) in response to its Consultation Paper on “Draft Technical […]

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Topics: "delta" hedge administrator, affiliated market participants, agency basis, Asia, back testing, Basel Committee on Banking Supervision, Basel III, bespoke non-cleared trades, bilateral counterparty credit risk, bilateral non-cleared OTC derivatives transactions, capital, CCP, CCP governing bodies, CDS, central clearing, central counterparty, CFTC, clearing member, client protections, close-out, collateral, Commodity Futures Trading Commission, compliance, confidence interval, conflicts of interest, contractual relationship, Council of the European Union, counterparty risk, coupon, CPSS-IOSCO, CPSS-IOSCO standards, credit default swap, credit institutions, credit risk, Cross-Border, currency, Dealer, debt-security based swaps, default, default fund, Derivative Contracts, derivatives, derivatives contracts, direct client, Dodd-Frank Wall Street Reform and Consumer Protection Act, duplicative regulation, EMIR, ESMA, EU, EU Member State, Euro, Europe, European Parliament, European Securities and Markets Authority, European Union, execution, extraterritorial application of EMIR, extraterritoriality, fiduciary duty, financial instrument, floating rate payment, foreign exchange, gross basis, hedging, in-the-money swap, index, indirect clearing, indirect client, initial margin, interest rate derivatives, interest rate swaps, interlocking governance arrangements, internal controls, International Organization of Securities Commissions, interpretive guidance, IOSCO, LCH Clearnet, Lee Underwood, liquidation horizons, liquidity fragmentation, major swap participants, margin, margin requirements, margin valuation, market participants, maturity, money market instruments, mutual recognition, negative correlation, net basis, netting, non-cleared OTC derivatives, non-linear products, omnibus account, OTC derivatives, OTC derivatives market, OTC derivatives transactions, over-collateralization, over-the-counter derivatives, portability, portfolio compression, portfolio reconciliation, posted collateral, principal basis, Proprietary Trading Strategy, proprietary trading tools, public disclosure, Regulators, regulatory arbitrage, regulatory technical standards, risk committee, risk management, risk management framework, risk mitigation, risk profile, SEC, Securities and Exchange Commission, security-based swaps, segregation, self-regulatory organization, settlement prices, SRO, Stan Ivanov, straight-through processing, stress testing, swap dealers, swaps, systemic risk, third country regime, total return swaps, trade repositories, trading costs, trading venues, transaction fees, transparency, upfront payment, variation margin,

MFA Submits Comments to ESMA in Response to Draft Technical Standards on OTC Derivatives, CCPs and Trade Repositories03.19.12


MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) in response to its Discussion Paper on […]

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Topics: ADR aggregation, alternative liquidity providers, American Depository Receipt, back testing, back-to-back arrangements, bespoke and customized transactions, Cayman Islands, CCP, CCP Board, CCP committee, CCP data, CCP governance arragements, CCP's margin models, CCPs governance structure, central clearing, central counterparty, CFTC, chief compliance officer, chief risk officer, chief technology officer, clearing, clearing member, clearing members, clearing obligation, client clearing models, clients, Commodity Futures Trading Commission, competitive execution, confidence interval, confidentiality agreements, confidentiality of counterparty identities, conflicts of interest, counterparty and operational risk, counterparty credit risk, credit intermediary, credit intermediation, default, derivatives market, disclosure requirements, disclosure thresholds, Dodd-Frank Act, electronic trading, electronically processed, EMIR, ESMA, ESMA Discussion Paper on Draft Technical Stanards for the Regulation on OTC Derivatives CCPs and Trade Repositories, EU, EU member currency, Euro, European Securities and Markets Authority, European Union, executing counterparty, execution documentation, execution platform, extraterritorial application of EMIR, FCM, FIA, FIA-ISDA Cleared Derivatives Execution Agreement, foreign exchange derivatives, fund domicile, futures commission merchant, Futures Industry Association, guarantor, Hong Kong, indirect clearing, indirect clearing models, indirect contractual arrangements, interest rate derivatives, international harmonization of regulations, International Swap Derivatives Association, ISDA, liquidation period, lookback period, manager domicile, margin levels, margin requirements, market integrity, market location, market oversight, non-dealer representatives, non-default clearing members, notional amount, OTC derivatives, OTC derivatives market, over-the-counter derivatives, portability, principal of business, privacy and confidentiality of information, public dissemination of information, real-time processing, reasonably liquid traded instruments, record keeping, reference entity domicile, reference security, risk committees, risk management expertise, SD, SEC, Securities and Exchange Commission, security-based swaps, segregation, settlement currency, sound governance requirements, straight-through processing, stress tesing, sublimit, swap dealer, systemic risk, technical standards, third country counterparities, third country entities, trade acknowledgment, transaction volumes, underlying instrument,

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 Federal Reserve Bank of New York Outlining the Collaborative Work of Dealers and Buy-Side Institutions to Deliver Structural Improvements to the Global OTC Derivatives Market03.01.10


MFA, several buy-side firms, the major swap dealers and other industry trade associations jointly submitted a letter to global regulators, […]

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Topics: 2009 ISDA Credit Derivatives Determinations Committees Allocation Industry Working Group, asset class, Auction Settlement and Restructuring CDS Protocol, bilateral collateralization arrangements, bilateral derivatives transactions, buy-side firms, buy-side institution, caps, cash flow matching, CCP, CDS, CDS clearing, central clearing, central counterparties, central settlement, clearing house, collateralized portfolios, commodities, Confirmable LIfecycle Events, confirmation backlog reduction, credit default swap, credit derivatives, cross-currency swaps, DC, DC External Review procedure for the Cemex S.A.B de C.V. Restructuring Credit Event, default management, Depository Trust & Clearing Corporation, Dispute Resolution Procedure, dispute resolution procedures, DRP, DTCC, electronic allocation delivery functionality, electronic confirmation targest, Electronically Eligible Products, electronification, eligible trades, EMEA EM Options Annex, Equity Derivatives Markets, Europe, European Interdealer Fair Value Swap Annex, European Interdealer Index Swap Annex, European swaptions, Feasibility Study for Extending Collateralized Portfolio Reconciliations, floors, foreign exchange, forward rate agreements, G-14, G-20, global data repositories, global Interest Rate Reporting Repository, Implemenation Plan for Wider Market Roll-out, inflation swaps, initial margin, inter-dealer service, interest rate derivatives, International Swaps and Derivatives Association, Interoperability, IRRR, ISDA Credit Derivatives Determinations Committees, ISDA Governance framework, legal standardization, margin calls, Market Review of Collateralization, Master Confirmation Agreement, matching, MCA, mitigating operational risk, Modified Regstructuring Credit Event, netting, novation consent process, OIS, operational efficiency, OTC bilateral collateral processes, OTC derivatives, over-the-counter derivatives, Overnight Index Swaps, portability, processing standardization, product standardization, Raodmap for Collateral Management, rates allocation commitment, risk management, Roadmap for Collateral Management, segregation, settlement automation, single currency basis swaps, single name clearing, Small Bang, submission timeliness, Thomson Restructuring, trade date matching, transparency, Warehouse Trust, zero coupon swaps,
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