margin requirements Archives - Managed Funds Association

MFA Submits Coalition Follow-up Letter to SEC on CDS Portfolio Margin Concerns12.27.13

On December 27, MFA, the American Council of Life Insurers (ACLI), and the Alternative Investment Management Association (AIMA) (collectively, the […]

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Topics: SEC Mary Jo White, Securities and Exchange Commission, CDS, credit default swap, portfolio margining, buy-side, market participant, swaps, Security-Based Swap, ICE Clear Credit, initial margin, Managed Funds Association, American Council of Life Insurers, ACLI, AIMA, Alternative Investment Management Association, derivatives, single-name CDS, CDS index, investment portfolio, central clearing, voluntary clearing, Dodd-Frank Act, risk, broker-dealer, futures commission merchant, FCM, margin, transparency, CFTC, Commodity Futures Trading Commission, Counterparty, credit risk, clearing agency, dealers, volatility, IOSCO, mark-to-market, variation margin, competition, efficiency, capital formation, margin requirements, risk management, Basel Committee on Banking Supervision, SIFMA AMG, Futures Industry Association, FIA, John Ramsay, Division of Trading and Markets,

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

MFA Submits Comments on Basel-IOSCO Second Consultative Document on Margin Requirements for Uncleared Derivatives03.15.13

MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision […]

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Topics: Basel Committee on Banking Supervision International Organization of Securities Commissions, margin, margin requirements, non-centrally cleared derivatives transactions, Working Group on Margining Requirements, consultation paper, market participants, financial system, bilateral exchange, bilateral exchange of initial margin, bilateral exchange of variation margin, initial margin, variation margin, risk management, customized risk management tools, international harmonization of regulations, derivatives, physically-settling forwards, re-hypothecation, Counterparty, systemically-important non-financial entities, quantitative impact study, collateral, efficiency, master netting agreements, financial instruments, liquidity, counterparty credit risk, regulatory arbitrage, mark-to-market, banks, foreign exchange transactions, U.S. dollar, Euro, emerging market, credit derivatives, haircuts, hedging, Dodd-Frank Act, segregation, receiving party, risk, margining, central clearing, clearing, swap dealer, major swap participants, third-party custody arrangement, MF Global Inc., systemic risk, Risk Profiles, customer replicability, transparency, Broker, assets, commodities, asset class, netting, regulatory regime, diversification, netting agreements,

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: Securities and Exchange Commission SEC, margin, capital, segregation, Security-Based Swap Dealer, Major Security-Based Swap Participant, capital requirements, broker-dealer, risk, security-based swaps, customer collateral, Dodd-Frank Act, CFTC, Commodity Futures Trading Commission, Private Funds Managers, Investor Protection, regulation, international regulatory standards, efficiency, capital formation, liquidity, collateral, margin requirements, market participants, variation margin, netting, margining, Financial Industry Regulatory Authority, FINRA, international harmonization of regulations, regulatory arbitrage, federal register, bilateral exchange of variation margin, best practices, counterparty risk, systemic risk, risk management, portfolio margining, securities, cross-product master netting agreements, initial margin, financial system, asset class, counterparties, prudential regulators, leverage, derivatives, tri-party custodial arrangements, customer protection, omnibus segregation, default, fellow customer risk, legal segregation with operation commingling, LSOC, swap dealers, Major Swap Participant, Individual Segregation, buy-side firms, non-commercial end-users, hedge funds, credit risk, capital inefficiency, transparency, Basel Committee on Banking Supervision, International Organization of Securities Commissions, IOSCO, Working Group on Margining Requirements, central clearing, compliance, registered clearing agencies, mandatory clearing, compliance date, two-way margining, reform, collateral management, asymmetrical initial margin exchange, pension, endowments, university endowment, financial crisis, "too big to fail, too interconnected to fail, American International Group, AIG, House Committee on Financial Services, Ben Bernanke, Federal Reserve Board, 111th Congress, financial contagion, financial institutions, asymmetry, portfolio reconciliation, portfolio compression, Swap Trading Relationship Documentation, swap dealer, collateral management stystems, trading costs, complexity, settlement risk, credit default swap, CDS, OTC derivatives, forwards, repurchase agreements, Value at Risk, VaR, financial instrument, cross-margining, Options Clearing Corporation, Chicago Mercantile Exchange Holdings Inc., New York Portfolio Clearing LLC, LCH.Clearnet Ltd., customer replicability, proprietary information, reconciliation, market risk, haircuts, Cash Flow, pro-cyclical effects, creditworthiness, multiplier, customized risk management tools, sell-side firms, liquidation time horizon, product type, market practice, ISDA, U.S. dollar, settlement, money market instruments, eligible collateral, capital charge, Lehman Brothers, bankruptcy, bankruptcy estate, third-party custody arrangement, enhanced protections, Notice of Exclusive Control, Investment Company Institute, ICI, White Paper, Securities Industry and Financial Markets Association, SIFMA, liquidation, Federal Reserve Bank of New York, tentative net capital, dealers, Eric Chern, Chicago Trading Company, \, operational risk, Security-Based Swap Transactions, Darrell Duffie, Federal Reserve Bank of New York Staff Report No. 424, ICE Clear Europe Limited, segregation model, DCO, derivatives clearing organization, portability, insolvency, out-of-the-money, operational and legal commingling, default segregation model, MF Global Inc., Peregrine Financial Group, Fraud, investment risk, Russell Wasendorf, accounting, operational costs, Broker, Dealer, ISDA Margin Survey 2012, European Commission, European Parliament, Council of the European Union, central counterparty, CCP, trade repositories, commodity broker, Bart Chilton, Division of Clearing and Intermediary Oversight, Robert Wasserman, independent third party custodian, state bank regulator, state and federal laws,

MFA Submits Comment Letter in Response to Basel-IOSCO’s Consultative Document on Margin Requirements for Non-Cleared Derivatives09.28.12

MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision […]

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Topics: Basel Committee on Banking Supervision International Organization of Securities Commissions, IOSCO, margin, margin requirements, non-centrally cleared derivatives transactions, Working Group on Margining Requirements, derivatives, derivatives markets, margining, clearing, market participants, central clearing, risk management, initial margin, variation margin, best practices, liquidity, mandatory clearing, bilateral exchange, buy-side firms, segregated account, custodian accounts, hedge, hedge funds, netting, eligible collateral, portfolio margining, over-collateralization, mutually offsetting transactions, margin threshold, harmonization, uniformity, non-compliance, regulatory arbitrage, market advantage, phase-in period, implementation timeline, non-cleared derivatives, regulatory authorities, foreign exchange, swaps, forwards, risk profile, market infrastructures, liquidity characteristics, currency, Denominated in G7 Currencies, G7, cleared derivatives, systemic risk, systemic importance, systemically important, systemically important non-financial firm, liquidity costs, unlevel playing field, transparency, SIFI, systemic risk level, credit, unsecured credit extension, minimum transfer amount, MTA, prudentially regulated financial counterparties, two-way margining, standard practice, credit risk, clearing house, bilateral exchange of variation margin, market liquidity, credit default swap, CDS, novation, remaining party, party stepping out, party stepping in, novating parties, market value, Regulators, novation arrangements, liquidity mechanism, asset classes, liquidation, Dodd-Frank Act, European Union, EU, United States, ISDA, International Swaps and Derivatives Association, replacement transaction, market practices, cross-product master netting agreements, risk offsets, financial instruments, U.S. Treasury futures, Eurodollar futures, non-cleared interest rate swaps, repurchase agreements, correlated financial instruments, quantitative impact study, Portfolios, central counterparty, CCP, hedged portfolios, prudential regulators, risk characteristics, risk/reward profile, diversification, concentration limits, haircuts, segregation, third-party segregation, re-hypothecation, cost mitigation, Commodity Futures Trading Commission, CFTC, swap dealers, major swap participants, equities, delta, interest rates, CDS spreads, notional value, commodities,

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

MFA Files Joint Letter to CFTC Requesting a Time Extension for Compliance with Amendments Regarding Section 4.1304.30.12

MFA, IAA, and AIMA filed a letter requesting the CFTC grant an extension in time for compliance with the amendments […]

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Topics: Investment Adviser Association IAA, Alternative Investment Management Association, AIMA, Commodity Futures Trading Commission, CFTC, commodity pool operator, CPO, CPO registration requirements, commodity trading advisor, CTA, pool, swaps, Associated Persons, fingerprint cards, proficiency requirements, investment firms, market participants, portfolio analysis, registration, compliance, National Futures Association, NFA, commodity interests, electronic trading models, Form 8-R, Series 3 Exam, registration statement, hedging activities, Form 7-R, Dodd-Frank Wall Street Reform and Consumer Protection Act, Dodd-Frank Act, Third Party Service Providers, Securities and Exchange Commission, SEC, Form ADV, private pool, wholly-owned subsidiary, margin requirements, security-based swaps, credit default swap, CDS, margin, initial premiums, swap contracts, back testing, aggregate trading, net notional test, futures, options,

MFA Submits Comments to the Monetary Authority of Singapore on Proposed Regulations on OTC Derivatives03.26.12

MFA submitted a comment letter to the Monetary Authority of Singapore (MAS) in response to its Consultation Paper on Proposed […]

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Topics: Monetary Authority of Singapore MAS, OTC derivatives, over-the-counter derivatives, Consultation Paper on Proposed Regulation of OTC Derivatives, G20, OTC derivatives market, systemic risk, efficient capital flows, mandary clearing, clearing, bilateral market, risk management, derivatives transactions, trading mandate, liquid and standardized transactions, client access to clearing, clearing arrangements, margin methodologies, straight-through processing, central clearing, Commodity Futures Trading Commission, CFTC, Gary Gensler, Securities and Exchange Commission, Mary Schapiro, market participants, central counterparty, CCP, average notional value, clearing threshold, buy-side clearing, U.S. Federal Reserve Bank of New York, Dodd-Frank Wall Street Reform and Consumer Protection Act, Dodd-Frank Act, backloading, Financial Stability Board, FSB, international harmonization of regulations, swaps, European Union, EU, European Commission, ESMA, legal entity identifiers, confidentiality, transaction data, counterparty identification, customized and proprietary investment strategies, intellectual property, International Organization of Securities Commissions, IOSCO, foreign regulator, financial entities, non-financial entities, Singapore, Form PF, margin requirements, netting, trading costs, aggregate counterparty credit risk, settlement risk, commercial banks, dealers, money changers, registered insurers, non-centrally cleared derivatives transactions, margin determinations, liquidation horizons, fragmentation of liquidity, clearing house, counterparty risk, recognized clearing houses, clearing facilities, real-time processing, barriers to entry, non-dealer client representation, risk committees, G20 commitments, regulatory regime, duplicative regulation, U.S. Senate Committee on Agriculture Nutrition and Forestry, trade repositories, Securities and Futures Commission, Honk Kong Monetary Authority,

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

Comment Letter to CFTC on Customer Clearing Documentation, Timing of Acceptance for Clearing, and Clearing Member Risk Management09.30.11

MFA submitted a comment letter to the CFTC in response to its notices of proposed rulemaking on Customer Clearing Documentation […]

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Topics: central clearing of swaps systemic risk, counterparty credit risk, alternative liquidity providers, credit sub-limits, trilateral clearing agreements, futures commission merchants, FCM, swap dealers, SD, major swap participants, msp, executing counterparty, best execution, competitive liquidity, derivatives clearing organization, DCO, bilateral negotiation, market risk-based limits, margin requirements, screening, over-the-counter derivatives, OTC, transparency, real-time clearing, conflict-of-interest safeguards, affiliate clearing functions, buy-side market participants, Designated Contract Market, DCM, Swap Execution Facility, SEF, credit intermediation, Chicago mercantile exchange, CME, ClearPort, Intercontinental Exchange, ICE, Options Clearing Corporation, anonymity, designation notice, Futures Industry Association, FIA, International Swaps and Derivatives Association, Inc., ISDA, FIA/ISDA Cleared Derivatives Execution Agreement, bunched trade, bundled trade, standby clearing arrangements, multi-fund complex, central limit order book,

MFA Comment Letters

Topic: margin requirements