MFA Comment Letters

Topic: leverage

MFA Submits Comments to the FSB/IOSCO on Assessment Methodologies for Non-Bank Non-Insurer Global SIFIs04.07.14


MFA submitted a comment letter to the Financial Stability Board and the International Organization of Securities Commissions in response to […]

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 […]

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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 Petitions the CFTC to Exclude Certain Employee Pools from the Definition of “Pool”08.30.12


MFA petitioned the CFTC to provide an exclusion from the definition of commodity “pool” for certain internally owned entities, including […]

MFA Submits Amicus Brief on Issue of Creditor Coordination06.29.12


On June 29, MFA filed an amicus brief in the 11th Circuit en banc review of the CompuCredit case.  At […]

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Topics: Aidan Synnott Ali Stoeppelwerth, alternative investment industry, anticompetitive, Arizona v. Maricopa County Medical Society, Bankruptcy Code, Bankruptcy Filing, banks, bilateral monopoly, Board of Governors of the Federal Reserve System, Bondholder, bonds, borrowers, Brendy Kuehne, Broad. Music Inc. v. Columbia Broadcasting Sys. Inc, broker-dealer, Bus. Elecs. Corp. v. Sharp Elecs. Corp., capital, capital formation, chilling effect, Classic Cheesecake Co. Inc. v. JPMorgan Chase Bank NA, collective action risks, competition, Compucredit Holdings Corporation v. Akanthos Capital Management LLC, Conrad Duberstein, contract, contractual relationship, corporate bonds, credit market, credit squeeze, creditor, creditor coordination, Daniel Crane, debt instruments, debtor, distressed debt, Edward Altman, Falstaff Brewing Corp. v. New York Life Ins. Co., FDIC, Federal Deposit Insurance Corporation, Federal Trade Commission v. Brown Shoe Co., Federal Trade Commission v. Indiana Federation of Dentists, Federal Trade Commission v. Superior Court Trial Lawyers Association, Financial Crisis Inquiry Commission, Finnegan v. Campeau Corp., Glenn Merrick, hedge funds, high-velocity market, institutional lender, interest rates, investment banks, Ireland v. Craggs, John Coffee Jr., Judge Easterbrook, Leegin Creative Leather Products Inc. v. PSKS Inc., leverage, Loan Syndications and Trading Association, low-velocity market, Marcel Kahan, Maris Distrib. Co. v. Anheuser-Busch Inc., market power, maturity date, Michael MacKenzie, Moses Silverman, National Collegiate Athletic Association v. Board of Regents, New York University Salomon Center, Nicole Bullock, Northwest Wholesale Stationers Inc. v. Pacific Stationery & Printing Co., Office of the Comptroller of the Currency, Palmyra Park Hosp. Inc. v. Phoebe Putney Memorial Hospital, par value, per se rules, pre-packaged bankruptcy, price competition, price-fixing, primary market, Reisner v. General Motors Corp., Reiter v. Sonotone Corp., risk portfolio, secondary loan markets, securities firms, Securities Industry and Financial Markets Association, Shared National Credit Review, Sharon Steel Corp. v. Chase Manhattan Bank NA, SIFMA, Smith v. The Ferncliff, State Farm Mutual Auto. Ins. Co. v. Physicians Injury Care Center Inc., Stern School of Business, syndicated loan market, systemic risk, Tomotaka Fujita, Twin City Pipe Line Co. v. Harding Glass Co., U.S. Court of Appeals for the Eleventh Circuit, U.S. Court of Appeals for the Second Circuit, U.S. Court of Appeals for the Seventh Circuit, Unijax Inc. v. Champion International Inc., United Airlines Inc. v. U.S. Bank NA, United States v. Giordano, United States v. Topco Assocs Inc., Volt Info. Scis. Inc. v. Board of Trs. of Leland Stanford Jr. University, William Klein,

MFA Submits White Paper to European Commission on Shadow Banking06.01.12


On June 1, MFA submitted a white paper on hedge funds and shadow banking in response to the European Commission’s […]

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Topics: "too big to fail ABCP conduits, absolute risk, AIFMD, Alternative Investment Fund Managers Directive, asset classes, asset-backed commercial paper conduits, asset-backed securities, assets under management, AUM, Background Note, Background Note "Shadow Banking: Scoping the Issues", bank-like activities, bank-like regulation, bankruptcy, banks, Board of Governors of the Federal Reserve System, broker-dealer, Brookings Institution, Bureau of Economic Analysis, central clearing, CFTC, chief compliance officer, collateral, Columbia University, commodity futures contracts, Commodity Futures Trading Commission, commodity pool, commodity trading advisor, convertible arbitrage, corporate bonds, corporate fixed income instrument, counter-cyclical, counterparties, credit arbitrage strategies, credit cards, credit hedge funds, credit intermediation, creditor, CTA, demand deposit accounts, Department of the Treasury, deposit-like characteristics, derivative transactions, derivatives, derivatives market, direct lending, direct loan market, discount windows, distressed restructuring strategies, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, Doug Elliott, EMIR, equity investors, EU, EU Member State, European Commission, European Market Infrastructure Regulation, European Union, financial industries, financial institutions, financial market, Financial Services Authority, Financial Stability Board, Financial Stability Oversight Council, fixed income - asset backed, fixed income - convertible arbitrage, fixed income - corporate, fixed income instruments, Form ADV, Form PF, FSA, FSB, FSOC, fundamental credit analysis, G20, gates, government bonds, government insurance, Green Paper "Shadow Banking", hedge fund counterparties, hedge fund industry, hedge fund managers, Hedge Fund Research, hidden leverage, House Financial Services Subcommittee on Financial Institutions and Consumer Credit, ICI, initial margin, insider trading, instant liquidity funds, institutional investment manager, investment advisers, Investment Company Institute, investment strategies, investor, leverage, leverage ratio, leveraged loan markets, liquidity, liquidity protections, liquidity transformation, loans, lock-up periods, Long Term Capital Management, Lord Adair Turner, major swap participants, margin, market based regulations, Markets in Financial Instruments Directive, Master Limited Partnership, maturity tra, maturity transformation, MiFID, money market funds, mutual funds, mutual funds management, non-bank financial insitutions, nonbank credit intermediation, Office of Financial Research, OFR, originator, OTC derivatives, over-the-counter derivatives, PIPE, pricing discrepancy, private equity, private investment in public equity, private issue/Regulation D strategies, property-casualty insurance, prudential regulation, public company equity securities, quantitative strategies, RAUM, real estate, receivables, redemption terms, Regulation D, regulatory arbitrage, regulatory assets under management, regulatory framework, relative value, relative value - multi-strategies, risk analysis, risk management, SEC, secured borrowings, secured financing, Securities and Exchange Commission, segregation, shadow banking, shadow banking system, side pockets, SIFI, SIV, small and medium-sized enterprises, SME, sophisticated investors, state securities regulators, structured investment vehicles, swap dealers, swaps, systemic risk, systemically important financial institution, tangible financial commitments, taxpayer, the Fed, total return swaps, transparency, U.S. Securities Laws, uncollateralized loans, United Kingdom, variation margin, venture capital funds, Volcker Rule,

MFA Submits Letter to IRS on Proposed Rules on Dividend Equivalent Payments04.06.12


MFA submitted a comment letter to the Internal Revenue Service on the IRS proposed rules under Section 871(m) of the […]

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Topics: 30 day liquidity 90-Day Rule, abusive practices, ADTV, anti-abuse rule, average daily trading volume, Bloomberg, broad-based indices, cascading witholding taxes, common stock, compliance restrictions, contractual representations, credit, crossing, crossing transactions, customized index, delta, delta one instrument, delta-one, delta-one instruments, Department of the Treasury, derivatives, derivatives transactions, direct or indirect "cross", dividend equivalent, dividend equivalent payments, dividend payment, dividend swaps, equity linked derivatives markets, equity-linked swaps, extraordinary dividend, FATCA, full notional amount, future dividend flow, futures, gross witholding, hedge, high-frequency trading, illiquid securities, in connection with standard, in the market, individual trade determinations, Internal Revenue Service, internal tax review system, International Swaps and Dealers Association, investment algorithms, investment fund, IRS, ISDA, leverage, long equity swap, long-party, market forces, market participants, market sector, multi-strategy fund, non-delta one instrument, non-U.S. persons, OCC, offsetting position, options, Options Clearing Corporation, options contracts, options market, ordinary divident, OTC option, out-of-the-money, outstanding positions, overwitholding, preferred stock, private funds, proprietary index, public float, public float test, real-time identification of offsetting positions, recognized independent index publisher, retested, short-party, short-term trades, single strategy fund, SNPC, special dividend, special dividends, specified notional principal contracts, strike price, swaps, synthetic exposure, tax avoidance, trading strategies, underlying security, undue market disruption, witholding agent,

MFA Response to FSA Discussion Paper on Implementation of the AIFMD03.23.12


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Topics: Advanced Method AIFMD, AIFMD firm, Alternative Investment Fund Managers Directive, audit function, CAD-defined terms, capital requirements, CDS, CESR Guidelines on Risk Management and the Calculation of Global Exposure and Coutnerparty Risk for UCITS, chief compliance officer, compliance function, conflicts of interest, CRD3 framework, depositary, depositary liability, Dodd-Frank Act, ESMA, EU Passport, EUR denominated bonds, European Central Bank, European Securities and Markets Authority, exchanges, external valuer, family investment vehicle, family relationship, FCA, FCA Approach Document, Final Advice on the AIFMD, Financial Services Authority, foreign exchange, Form PF, FSA, FSA Discussion Paper "Implementation of the Alternative Investment Fund Managers Directive", FSA Principles for Business, FSA Remuneration Code, functional and hierarchal independence, functional and hierarchical separation, hedge funds, hedging arragements, institutional investors, interest alignment, interest rate risk, internally managed AIF, internationally coordinated approach to reporting, investor capital, IPRU (INV), less than fully invested, letter-box entity, leverage, limited partnership, liquidity requirements, marketing, Member State competent authorities, MiFID, MiFID firm, MiFID investment services, MiFID portfolio managers, NAV, NAV per share, net asset value, net assets under management, non-EU AIFM, PII requirements, portfolio management, portfolio management personnel, portfolio risk, preferential treatment, prime brokers, private placement, professional indemnity insurance, professional investors, professional negligence, proportionality principle, proprietary business information, public offers, QIS disclosure requirements, qualitative risk limit, redemption terms, regulatory requirements, regulatory risks, remuneration guidelines, remuneration provisions, retail consumers, retail customers, retail investors, reverse solicitation process, risk management, risk/return profile, SEC, Securities and Exchange Commission, segregated account, side letters, single AIFM, swap data warehouses, SYSC 10 of the FSA Handbook, third country, third country managers, tier 4 firm, UCITS Directive, UCITS investors, UK AIFM, unregulated CIS, valuation oversight duties, valuation procedures, Value at Risk, VaR methodology,
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