MFA submitted a supplemental comment letter to the SEC in response to its reopening of the comment period on its […]
MFA submitted a comment letter to the SEC on its proposed rules on Clearing Agency Standards for Operation and Governance. […]
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Comment Letter on Proposed Regulation for Ownership Limitations and Governance Requirements for Security-Based Swap Clearing Agencies, Security-Based Swap Execution Facilities, and National Securities Exchanges With Respect to Security-Based Swaps Under Regulation MC04.29.11
MFA submitted a supplemental comment letter to the SEC in response to its reopening of the comment period on its […]
Topics: Securities and Exchange Commission security-based swap clearing agencies, SBSCAs, national securities exchanges and security-based swap execution facilities, SBS entities, risk management, greater efficiencies, Investor Protection, transparency, security-based swaps, percentage requirements, compositional requirements, over the counter derivative markets, OTC, sophisticated derivatives product, direct and indirect clearing membership, dealer interests, management committees, RMCs, non dealer, customer representatives, balanced representation, dealers, independent directors, controlling majority, market-based evolution, lack of transparency, segregation model, mutualization of customer risk, omnibus customer accounts, SBS entity management, optimal capital, margin, cost management, risk management boundaries, risk-based criteria, ISDA, Markit Group Limited, LCH Clearnet, Intercontinental Exchange, Inc., The Clearing Corporation, ICE/TCC, material constraint, burden of proof, RMC subcommittee decisions, SEC,