MFA Comment Letters

Topic: liquidity requirements

MFA Coalition Submits Joint Letter to SEC and CFTC on CDS Customer Portfolio Margining05.10.13


MFA, the American Council of Life Insurers (ACLI), and the Alternative Investment Management Association (AIMA) (collectively, the “Associations”) submitted a […]

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Topics: ACLI AIMA, Alternative Investment Management Association, American Council of Life Insurers, arbitrage, backloading, broad-based indices, broker-dealer, buy-side participants, capital, capital formation, CDS, central clearing, CFTC, clearing, clearing agency, clearing mandate, clearinghouse, collateral, Commodity Futures Trading Commission, counterparty credit risk, counterparty risk, credit default swaps, credit risk, custody bank, DCM, DCO, dealers, derivatives, derivatives clearing organization, direct clearing members, directional portfolio, economic barriers, end-users, equity markets, excess margin, FCM, Federal Reserve Bank of New York, Financial Industry Regulatory Authority, FINRA, futures commission merchants, Gary Gensler, hedging, ICE Clear Credit LLC, ICE Trust, initial margin, initial margin requirements, insolvency, institutional custodian, interconnectedness, interest rate swaps, Investor Protection, iTraxx Europe, legal segregation with operation commingling, liquidation, liquidity, liquidity requirements, long-short strategies, LSOC, LSOC with excess, margin, margin requirements, margining, market efficiency, market participants, Mary Jo White, master netting agreements, narrow-based index credit default swap, net margin, New York State Banking Department, OCC, offsetting position, Options Clearing Corporation, portfolio margining, price competition, price distortion, proprietary strategies, registered clearing agencies, regulatory framework, risk management, S&P 500, SEC, Securities and Exchange Commission, security-based swaps, segregation, self-clearing members, sell-side firms, settlement, short straddles, single-name CDS, speculative position, straight-through processing, swaps, systemic risk, tri-party segregation arrangements, variation margin, volatility, voluntary clearing,

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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