MFA Comment Letters

Topic: Manipulation

Supplementary Letter to the SEC in Response to its Proposed Antifraud Rule with Respect to Security-Based Swaps03.29.11


MFA submitted a letter to supplement our December 23, 2010 letter to the SEC in response to its proposed antifraud […]

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Topics: anti-fraud rule assignment, assignments, automatic stay provisions, Bank of International Settlements, Bankruptcy Code, bankruptcy proceedings, bilateral contracts, BIS, capital formation, CDS market, clearing agreement, collateral, competition, context, conveyance of rights/obligations, corporate actions, corporate loans, cost-benefit analysis, counterparty defaults, credit default swaps, credit events, credit exposure, Deception, definitions, derivatives market, disruption events, equity exposure, equity linked forwards, equity-linked swaps, exchange, execution, extinguishment of rights/obligations, fair dealing, FCIC, financial crisis, Financial Crisis Inquiry Commission, Financial Stability Board, Fraud, high yield bonds, honest markets, institutional leveraged loans, interim payments, International Swaps and Derivatives Association Inc, investment grade bonds, investment grade loans, investor confidence, ISDA master agreement, LBO-related loans, legitimate market activity, legitimate market participation, leveraged loans, Loan market Review, Manipulation, material dislocation, material non-public information, maturity date, non-index multi-name credit default swaps, novations, premium payments, price discovery, price discovery process, price efficiency, primary debt issuance, primary participant, purchase, Reuters, sale, SEC, SEC v. Rotech, secondary participant, Securities and Exchange Commission, Securities Industry and Financial Markets Association, security based swap anti-fraud rule, security based swaps market, security-based swaps, single name credit default swaps, spread payments, statutory authorization, swap market, swaps market, systemic risk, termination, termination events, The Loan Syndications and Trading Association, total return swaps, transfer of rights/obligations, transferor, unallocated swaps, underlying shares, unwinds, US OTC derivatives market,

Comment Letter to the CFTC on its Proposed Core Principles and Other Requirements for Swap Execution Facilities03.08.11


MFA submitted a comment letter to the CFTC on its proposed Core Principles and Other Requirements for Swap Execution Facilities. […]

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Topics: annual review auction-based methods, available for trading, bilateral trading, bilateral trading environment, block size, block trade thresholds, block trades, cash position, CBOE futures exchange, CEA, central limit order variants, CFTC, chief compliance officer, cleared swaps, Commodity Futures Trading Commission, competition, complete audit trail, conflicts of interest, congestion, connectivity, credit default swaps, crossing, daily trading records requirements, data analysis, DCM, dealer-to-customer platforms, debt instrument, Designated Contract Market, discreet contract, electronic platform, emergency procedure, exchanges, exchanges for physical, exchanges for swaps, execution protocol, fixing, flexibility, futures position, grace period, grandfather relief, institutional investors, interstate commerce, ISDA, joint the trade, large notional transaction size threshold, limit order, linked transactions, liquidity, liquidity characteristics, major swap participants, Mandatory Execution Requirement, mandatory minimum required recipients, mandatory objective criteria, mandatory transparent criteria, Manipulation, market efficiencies, market liquidity, market-based competition, matching, matching traders, minimum block sizes, minimum block threshold, multiple-to-multiple trading venues, non-continuous liquidity, off-market transactions, one-to-one voice services, open outcry trading pits, order book, order book systems, OTC, OTC market, Over-the-Counter, Over-the-Counter Derivatives Markets, packaged transactions, permitted transactions, physical contract, physical position, price distortion, public information, quote requesters, quote-requesting participant, real-time public reporting of swap transaction data, recordkeeping requirements, regulatory efficiencies, reporting requirements, request for quote, required transactions, responsive quote, resting bids, RFQ, RFQ response period, RFQ system, Rulebook, SB SEF, security-based swap execution facility, SEF trading platforms, SEFs, SIFMA, single joint transactions, sporadic liquidity, swap data repositories, swap execution, swap execution facilities, timing delay, trading venues, transparency, voice-based system, voice-based trading, widened bid/offer spreads,

MFA Letter to FTC on Prohibition of Energy Market Manipulation Rule05.20.09


MFA jointly with FIA, CME Group, ICE and NFA submitted a letter to the Federal Trade Commission regarding its “Prohibition […]

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Topics: 1145 (7th Cir. 1982) 2002 WL 32135703, 2006 WL 778640 (S.D. Tex. March 24 2006), 250 N.W.2d 583 (Minn. 1976), 276 F.3d 583 (D.C. Cir. 2001), 276 F.3d at 591, 276 F.3d at 592, 420 F Supp.2d 1043 (N.D. Cal. 2006), 512 U.S. 594, 531 S.W.2d 805 (Tex. 1975), 537 U.S. 820, 546 F.2d 1361, 556 S.W.2d 420 (Ark. 1977), 677 F.2d 1137 (7th Cir. 1982), 706 (2d Cir. 1987), 823 F.2d 702, 883 F.2d 537 (7th Cir. 1989), accounts, Advanced Notice of Proposed Rulemaking, agents, agricultural feed-stocks, Agriculture Department, Amaranth, anti-manipulation protections, anti-manipulation system, Board of Trade of City of Chicago v. SEC, Board of Trade of City of Chicago v. SEC 677 F.2d 1137, Board of Trade of the City of Chicago, brokers, CBOT, CEA, CFTC, chain of precedent, Chciago Mercantile Exchange Inc., Chicago Mercantile Exch. v. SEC, Clayton Brokerage Co. v. Mouer, CME Group Inc., COMEX, commercial market, commodities, Commodity Exchange, Commodity Futures Trade Commission, commodity pool operators, commodity prices, commodity trading advisors, compliance burden, congressional grant, contract markets, contractual privity, contradictory requirements, corn, corporate disclosures, counterparties, crude oil, customer protection, DOE, Donald S. Clark, emissions credit, Energy Department, energy futures, energy markets, Environmental Protection Agency, EPA, ethanol, exclusive jurisdiction provision, exclusive jurisidiction provision, exclusive regulatory authority, false reports, Federal Energy Regulatory Commission, federal register, Federal Trade Commission, FERC, FIA, forward market business activities, fraud proscriptions, FTC, FTC v. Roberts, futures exchange, futures group, Futures Industry Association, gasoline, ICE, ICE Futures Canada, ICE Futures of Europe, ICE Futures U.S., Inc., instruments, IntercontinentalExchange, intermediaries, International Trading Ltd. v. Bell, Jeffrey Sprecher, Jerrold E. Salzman, John M. Damgard, Ken Roberts Co. v. FTC, limited-purpose national securities association, Manipulation, Market Manipulation Rulemaking, merchants, Minnesota v. Coin Wholesalers, National Futures Association, New York Board of Trade, new York Mercantile Exchange Inc., NFA, No. 01-1772, non-futures, non-petroleum based commodities, NYMEX, options trading, over-the-counter energy trading platform, Part 317, petroleum distillates, price artificiality, price discovery, price effects requirements, registered account executives, regulatory, resource limitations, safe harbor, SEC v. American Commodity Exch., SEC vs. Hopper, speculative limits, statutory authority, sugar, Thomas W. Sexton, Trichilo v. Sec'y of Health & Human Servs., U.S. Court of Appeals for the Seventh Circuit, United States Congress, US vs. Reliant Energy Services, USDA, wholesale markets, wholesale purchase, Williamson v. United States, Winnipeg Commodity Exchange,
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