MFA Comment Letters

Topic: market manipulation

Comment Letter to the CFTC in Response to its Request for Comments on Position Limits for Derivatives03.28.11


MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains […]

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Topics: account aggregation requirements active trading program, aggregate all-months-combined, aggregate single-month, aggregate spot-month position limits, agricultural commodities, agricultural model, annual limits, annual recalculation methodology, annual renewal based exemption, application based exemption, approval based exemption, arbitrage exemption, Artificial limits, asset manager, audit, Barclays Capital, Bauer College of Business, benchmark contracts, Berlin wheat, bona fide hedger, calendar-spread exemption, cash market risk, cash market transaction, cash position, cash-settled contracts, CBOT, CFTC, CFTC docket no. 08-02, CFTC docket no. 11-05, Chicago onions, class limits, cleared bilateral contracts, CME, commercial hedgers, commercial participants, Commission Energy Complex Report, Commodity Futures Trading Commission, commodity market, commodity pool operator, commodity trading advisor, commodity trading advisors, common parent, conditional-spot month limit, control standard, corporate enterprises, CPO, Credit Agricole, cross-ownership of traders, crowding out provision, crude oil futures, CTA, CTFC Inter-Agency Task Force on Commodity Markets, DCMs, deferred month positions, deliverable supply, delivery point, delta, derivatives, directional position, disaggregation relief, disclosure documents, disorderly markets, eligible entity, energy market infrastructure, energy price volatility, Energy Risk, enforcement, enumerated agricultural commodities, equity interest, excessive speculation, FCMs, federal limits, financial cal spread options, financial institution, forward position, front month position, funds of funds, future commission merchants, futures, futures class all-months-combined, futures class single-month, futures market, GAO, global commodity, Global Energy Management Institute, hedge funds, hedging transaction, HH natural gas, HM Treasury Global Commodities, House Committee on Agriculture, hypothetical portfolios, IMF World Economic outlook, IMG, independent account controller exemption, independent third party, independently controlled accounts, independently controlled and managed trader, index fund manager, individual class rules, inter-commodity spread exemption, inter-commodity spread transactions, interest rates, International Organization of Securities Commission, interstate commerce, IOSCO, IOSCO Technical Committee, Jacks Study, JP Morgan, KCBOT, large trader data, last day swaps, legacy position limits, liquid price discovery, liquidity provisions, long positions, market depth, market liquidity, market manipulation, market surveillance, metal commodity, no-action relief, non-cleared bilateral contracts, non-financial entity exemption, non-spot position limits, NYBOT, NYMEX crude oil price, NYMEX Henery Hub Natural Gas contract, OECD Food, OECD publishing, offsetting positions, open interest, open interest formula, operating company, option contract, options, order routing arrangement, OTC, outright positions, passive investors, passive trading program, pension plan, penultimate swaps, percentage interest, physical cal spread options, physical commodity, physical commodity deliverable, physical options, physically delivered contracts, Pirrong Testimony, PKVerleger LLC, pool participant, pool participant exemption, position limits, position visibility, pre-existing position exemption, price discovery, price risk, price spikes, price volatility, private equity investments, real-time basis, referenced contracts, regulatory oversight, reporting obligation, reporting requirements, risk management, risk transfer, risk-shifting market, rounding, seasonal variation, seasonality, self-executing disaggregation, short positions, significant price discovery contracts, speculative investment, speculative trading ventures, spot month, spot-month position limits, squeezes, statement of reporting trader, stock indices, submarket, supply and demand, surveillance, swap contract, swap dealer hedge exemption, swaps class all-months-combined, swaps class single-month, swaptions, The Economist, U.S. dollar, U.S. futures exchange, UK Treasury, university endowment, University of Calgary, University of Houston, Wall St. Journal, WTI,

Letter to the European Commission in Response to its Consultation Paper, Review of the Markets in Financial Instruments Directive (MiFID)02.02.11


MFA submitted comments to the European Commission in response to its Consultation Paper, Review of the Markets in Financial Instruments […]

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Topics: "strict equivalence" regime accurate price discovery, actionable IOIs, affirmative and negative obligations, aggregate open interest/notional amount, AIFM directive, algorithmic trading, alternative investment fund managers, alternative trading systems, APAs, approved publication arrangements, arbitraging, article 4(8) of MiFID, Asian Markets, asset managers, ATSs, automated execution technology, automated trading, banks, block sized trades, Bloomberg L.P., broker dealers, broker-dealer capital, brokers, capital flows, capital formation, cash balance, CCP, CDS market, certificates, CESR, circuit breakers, client identifier, co-location facilities, commodity derivatives, commodity derivatives market, composite quotation system, comprehensive notional data, comprehensive price date, concentrated risk solution, confidentiality obligation, conflicts of interest, Congress, consolidated core data, Consolidated Tape, Consolidated Tape Association, consolidated transaction reporting system, consultation papers, contract, core date, cost-effective manner, cost/benefit analysis, CQ plan, credit default swaps, credit flows, daily trading volume threshold, dark pools, data consolidation, deep market, depositary receipts, depth of market quotations, depth-of-market fees, derivatives position, direct market access, Disclosure, due diligence obligations, electronic market-making, electronic trading platforms, EMIR, equity investors, equity markets, equivalence mechanism, ESMA, EU, European Commission, European Commission on Standardisation and Organised Platform Trading of OTC Derivatives, European Commission Request for Additional Information in relation to the Review of MiFID, European Commission's report of Sovereign CDS, European Consolidated Tape, European Market Infrastructure Regulation, European OTC derivatives markets, European Union, ex-ante disclosure, ex-post disclosure, exchange traded funds, exchange trading, exchange-traded products, financial institutions, financial regulatory system, Financial Stability Board, flash crash, fleeting arbitrage opportunities, G20, global connectivity infrastructure, Google, hard position limits, harmonised position information, hedge funds, hedgers, HFT, HFT trades, high frequency trading, horizon strategies, indications of interest, information requirements, insurance companies, inter-market arbitrage, International Swaps and Derivatives Association, inventory risk, investment strategies, investor confidence, Investor Protection, IOIs, ISDA, latency, lending flows, level playing field, limit down system, limit orders, limit up system, liquid derivatives, liquid market, liquidity, liquidity provision requirements, low latency technology, low latency technology chain, margin requirements, market connectivity intermediaries, market data, market disorder, market efficiency, market impact, market makers, market manipulation, market stability, market turmoil, market-wide single stock circuit breakers, Markets in Financial Instruments Directive, mechanical imposition, member states, MiFID, MiFID framework directive, minimum duration of orders, minimum quantitative threshold, minimum tick sizes, national best bid and offer, National Market System, NetCoalition, NetCoalition v. Securities and Exchange Commission, nexus, non-equity instruments, non-EU asset managers, non-EU investment firms, non-EU markets, non-hedging, non-HFT trade, non-retail clients, opaque market centers, order flow, order stubs, order-slicing methodologies, Organised Trading Venues, OTC, OTC contract, physical commodity markets, portfolio manager, position management, position-level data, post-trade reporting proposals, post-trade transparency, pre-trade checks, pre-trade transparency, pre-trade transparency waivers, price discovery, price movement, proprietary strategies, quotations, reasonable threshold, reduced transaction costs, regulatory "tax, regulatory authorities, regulatory framework, regulatory transparency thresholds, reporting obligations, reporting protocols, reporting regimes, retail client, risk capital, risk controls, risk exposure, risk management, risk warnings, safeguards, SEC, Securities and Exchange Commission, securities financing transaction, Securities Industry and Financial Markets Association, security-based derivatives, sharp shoot, short-term price swings, sovereign CDS, specified maximum execution speeds, speed bumps, stale orders, statutory obligation, strategy holding periods, strict equivalence, sufficiently liquid, summary disclosure, surveillance tools, systemic risk, systemic risk grounds, technological innovation, technology-driven market makers, third country firms, third country regime, third party information vendors, title transfer collateral arrangement, title transfer collateral arrangements, trade repository, trader ID, trading delays, transaction report, transparency directive, UCITS, UCITS Directive, UK Treasury and Financial Services Authority, ultra low-latency technology, unilateral bans, US markets, US Securities Industry Automation Corporation, volatility, waivers, Yahoo Inc,

Comment Letter to CFTC Responding to Proposed Regulations to Implement Federal Speculative Position Limits for Futures and Options Contracts04.26.10


MFA submitted comments to the CFTC in response to its request for comments on its proposed rule on Federal Speculative […]

MFA Comments to the “Over-the-Counter Derivatives Markets Act of 2009”11.09.09


MFA submitted a letter to the Department of the Treasury regarding the Obama administration’s legislative proposal titled the “Over-the-Counter Derivatives […]

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Topics: AAA credit rating AIG, airline, American International Group, Bankruptcy Code, bankruptcy-remote, capital formation, capital restrictions, cash-settled contracts, central clearing, central clearinghouse, CFTC, collateral segregation, commodity, Commodity Futures Trading Commission, credit risk, custodian, dealers, Department of the Treasury, derivatives clearing organizations, derivatives transactions, end-users, endowments, energy companies, Enron Corporation, exchange trading, exchange-traded products, Gary Gensler, hedge funds, hybrid market, initial margin, institutional investors, insurance companies, ISDA product definitions, LBIE, legacy standardized swaps, Lehman Brothers, local governmental entities, Long Term Capital Management, Major Swap Participant, market manipulation, non-clearable trade, non-cleared swap transactions, non-dealer entities, Obama Administration, OTC derivatives, OTC derivatives market, over-the-counter derivatives, Pension Funds, physically-delivered commodities, position limits, pre-merger notification regime, private funds, proprietary assets, registered derivatives clearing organization, regulatory framework, risk management, SEC, Securities and Exchange Commission, securities dealers, securities market, security-based swaps, segregation, substantial net position, substantial unsecured net position, swap dealers, swap market participant, thrift and insurance holding company, trade and position reporting, unsecured current credit exposure, utilities, variation margin,

MFA Comments to CFTC on Proposed Rulemaking on Significant Price Discovery Contracts on Exempt Commercial Markets02.10.09


MFA submitted comments to the CFTC regarding its proposed rulemaking on significant price discovery contracts on exempt commercial markets.  MFA […]

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