MFA Comment Letters

Topic: Pension Funds

MFA Submits Comments to USTR on Mexican Bankruptcy Law for Trade Negotiations09.04.12


MFA submitted comments to the U.S. Trade Representative (“USTR”) raising concerns with the Mexican Business Reorganization Act as demonstrated by […]

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

Comment Letter Responding to FSB’s Background Note, ‘Shadow Banking: Scoping the Issues’05.16.11


MFA submitted a comment letter in response to the FSBs Background Note on Shadow Banking. In our letter, we discussed […]

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Topics: ABCP conduits asset concentration, asset management structures, Background Note, bank holding companies, bank/broker counterparts, banks, borrowing arrangements, broker dealers, collateral, concentration of assets, counterparty risk management, Counterparty Risk Management Policy Group, credit intermediation chain, derivatives contracts, direct regulation of entities, Distribution/Wholesale Funding, Financial Stability Board, FSA, haircuts, hedge fund adviser, hedge fund borrowings, hedge fund industry, hedge fund leverage, highly leveraged financial institutions, individual adviser, initial margin, insurance companies, interconnectedness of hedge funds, investors, large corporate investors, legal separation of different funds, liquidity transformation, Long Term Capital Management, long-only mutual funds, low leverage, LTCM, macro-prudential approach, manage liquidity risk, margining process, mark-to market margining, maturity transformation, mutual funds, non-bank institutional investors, nonbank financial institutions, off-balance sheet vehicles, Pension Funds, private equity funds, regulation, regulatory arbitrage, regulatory arbitrage concerns, repo collateral, repo liabilities, repo sellers, secured basis, secured borrowings, shadow banking system, Shadow Banking: Scoping the Issues, short term liability, stable capital, systemic impact of hedge funds, systemic risk concerns, The UK Financial Services Authority, U.S. President's Working Group on Financial Markets, U.S. Securities and Exchange Commission,

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,
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