portability Archives - Managed Funds Association

MFA and AIMA Submit Joint Letter on FSB Consultation on Key Attributes of Resolution Regimes for Non-Bank Financial Institutions10.15.13

MFA and AIMA submitted a joint letter to the Financial Stability Board (IOSCO) in response to its consultative document on […]

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Topics: AIMA Alternative Investment Management Association, Financial Stability Board, FSB, IOSCO, International Organization of Securities Commissions, resolution authority, collateral, clearing member, clearing, mandatory clearing, systemically important financial institution, SIFI, taxpayer, regulatory framework, risk management, OTC derivatives, trade repositories, Dodd-Frank Act, European Parliament, Council of the European Union, default, liquidation, ex ante measures, haircuts, margin haircut, G20, variation margin, transparency, market participants, buy-side, market infrastructures, default waterfall, title transfer collateral arrangement, security arragements, systemic risk, orderly liquidation, prudential regulators, bail-in, initial margin, bankruptcy law, Securities and Exchange Commission, SEC, CFTC, Commodity Futures Trading Commission, buy-side participants, market maker, dealers, sell-side firms, commodity, risk-neutral, physical commodity, Security-Based Swap Dealer, Major Security-Based Swap Participant, capital requirements, broker-dealer, mark-to-market, in-the-money swap, liquidity, EMIR, risk committee, segregation, portability, Derivative Contracts, European Union, EU,

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 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 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 SEC Responding to Proposed Rule Related to Security-Based Swap Clearing Agencies, Security-Based Swap Execution Facilities, and National Securities Exchanges11.26.10

MFA submitted a comment letter in response to the Securities and Exchange Commissions (SEC) proposed rule on Ownership Limitations and […]

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Topics: ownership limitations governance requirements, security-based swap clearing agencies, Security-Based Swap Execution Facilities, National Securities Exchanges, regulation MC, SBSCA, SBS, SB SEF, risk management, Investor Protection, Commodity Futures Trading Commission, CFTC, derivatives, derivatives market, market fragmentation, clearing, over-the-counter security-based-swap market, OTC security-based-swap market, derivatives clearing organizations, DCO, designated contract markets, swap execution facilities, SEF, DCM, conflict of interest, bilateral settlement, fiduciary obligation, fair pricing, risk committee, regulatory oversight committee, non dealer, customer representative, controlling majority, independent director, SBS exchange boards, SBS exchange committees, voting interest focus alternative, Voting Rights, clearing member, self-regulatory, close-out, transfer, netting, portability, straight-through processing, four-way execution, transparency, electronic trading, price discovery, liquidity,

Comment Letter on CFTCs Proposed Rule Related to Requirements for Derivatives Clearing Organizations, Designated Contract Markets, and Swap Execution Facilities Regarding the Mitigation of Conflicts of Interest11.17.10

On November 17, MFA submitted a comment letter on the CFTCs proposed rule related to Requirements for Derivatives Clearing Organizations, […]

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Topics: derivatives clearing organizations designated contract markets, Mitigation of Conflicts of Interest, Market Reform, Designated Clearing Organizations, DCOs, Designated Contracts Markets, DCMs, swap execution facilities, SEFs, market integrity, swap contracts, Clearing and Trading, Product Expansion for Cleared Swaps, bilateral settlement, Clearable Swaps, DCO governance, margin requirements, Membership Access, clearing, execution, transparency, competition, Liquidity of Cleared Swaps, conflicts of interest, enumerated entities, Consolidated Assets, Board of Governors of the Federal Reserve System, Public Directors, fiduciary duty, Express Obligation, Risk Management Committee, First Alternative, Voting Equity, Voting Control, Alternative, aggregate limit, Proposed Rule's Waiver Procedure, Clearing Regime, Healthy Competition, inter alia, Anti-Competitive Incentives, Direct Liquidity, Securities and Exchange Commission, SEC, Rulemaking, Coordinate and Reconcile, swaps, security-based swaps, Contract Structure, Principle-to-Principle, close-out, transfer, netting, Third Party Services, Additional Fees, portability, Portability of a Portfolio, Complete Portfolio, straight-through processing, counterparty risk, Executing Dealer, four-way execution, anonymity, Intra-Day Execution, Suitability for Electronic Trading, Barriers to Electronic Trading, Execution Format,

MFAs Response to Proposed Regulation of OTC Derivatives, Central Counterparties and Trade Repositories11.11.10

MFAs Response to Proposed Regulation of OTC Derivatives, Central Counterparties and Trade Repositories

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Topics: Proposed Regulation of OTC Derivatives European Union, central clearing, derivatives market, European Commission, Council on OTC Derivatives, Central Counterparties and Trade Repositories, Over-the-counter Derivative Market, OTC, Risk Management Activities, Market Particpants, Class of Derivatives, clearing, Manadatory Clearing Obligation, interest rate swaps, IRS, central counterparties, CCPs, European Securities and Markets Authority, ESMA, European Parliament, Council of Ministers, financial counterparty, Alternative Investment Fund, investment manager, Derivative Contracts, clearing obligation, operational risk, counterparty risk, transparency, competition, Top Down, Bottom Up, Determination Process, Trade Reporting Obligations, risk mitigation techniques, Segregated Exchange of Collateral, Proportionate Holding of Capital, capital requirements, Collateral Posting, Segregate and Exchange Margin, Hold Capital, initial margin, variation margin, Mark-to-Market Changes, Follow-on Effects, Market Exposure, Maximum Time Lag for Confirmation, systemic risk, third country CCPs, Non-European Countries, non-discriminatory access, Interoperability, Equivalency Test, Cross-Border Efficiency and Consistency, risk committees, Effective Supervision, Co-Operation Arrangement, Particpation Requirements, Admissable Clearing Members, Standard Capital Requirements, segregation, portability, Protection of Client Positions and Collateral, U.S. Treasury and U.S. Commodity Futures Trading Commission, U.S. House of Representatives Committee on Financial Services, U.K. House of Lords, European Policymakers, Insolvency Regimes, Unwinding Costs, Swiftly Collapse Offsetting Positions, Optimal Netting, Derivative Contract's Lifecycle, client collateral, Risk Profiles, Financial Strength, default, Trigger, Shortfall, Unmanageable Risk, capital formation, Investment Policy, Highly Liquid Collateral, Minimal Credit Risk, Highly Liquid Financial Instruments, market risk, credit risk, Highly Liquid, Denominated in G7 Currencies, Government Securities, default procedures, confidentiality, trade repositories, competent authorities, reasonable threshold, nexus, Coordination with Third-Country Regulators, Central Banks,

Comment Letter to European Commission on Public Consultation on Derivatives and Market Infrastructures07.09.10

MFA submitted a comment letter in response to the European Commissions (EC) Consultation Paper on Derivatives and Market Infrastructures. In […]

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Topics: European Commission derivatives, market infrastructures, over-the-counter derviatives markets, OTC derivatives markets, hedge funds, capital flows, risk management, mandatory clearing, clearing, trading venues, central counterparties, CCP, Counterparty, systemic risk, bottom-up approach, central clearing, European Securities and Markets Authority, ESMA, risk committee, credit default swaps, CDS, index credit default swaps, corporate end-users, reporting requirements, electronic trading, risk mitigation, depository derivatives counterparties, capital levels, non dealer, client representatives, trading volume, credit exposure, counterparty risk, Securities and Exchange Commission, SEC, Treasury Department, Commodity Futures Trading Commission, CFTC, U.S. House of Representatives Committee on Financial Services, third party countries, Unwinding Costs, portability, contract lifecycle, segregation, collateral, working capital, prudential requirements, risk-based, transparency, European Union, EU, competition, jurisdictional-based requirements, trade repositories, trade reporting, reporting, transaction volumes, reasonable threshold, global financial system,

Comment Letter to Federal Reserve Bank of New York Outlining the Collaborative Work of Dealers and Buy-Side Institutions to Deliver Structural Improvements to the Global OTC Derivatives Market03.01.10

MFA, several buy-side firms, the major swap dealers and other industry trade associations jointly submitted a letter to global regulators, […]

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Topics: G-14 buy-side institution, over-the-counter derivatives, OTC derivatives, G-20, transparency, global data repositories, asset class, central clearing, segregation, credit default swap, CDS, portability, ISDA Credit Derivatives Determinations Committees, International Swaps and Derivatives Association, central counterparties, CCP, DC, product standardization, processing standardization, legal standardization, operational efficiency, mitigating operational risk, risk management, netting, bilateral collateralization arrangements, bilateral derivatives transactions, initial margin, electronification, credit derivatives, CDS clearing, Europe, buy-side firms, OTC bilateral collateral processes, ISDA Governance framework, 2009 ISDA Credit Derivatives Determinations Committees, Auction Settlement and Restructuring CDS Protocol, Small Bang, Modified Regstructuring Credit Event, Thomson Restructuring, DC External Review procedure for the Cemex S.A.B de C.V. Restructuring Credit Event, interest rate derivatives, Overnight Index Swaps, OIS, single name clearing, dispute resolution procedures, Raodmap for Collateral Management, collateralized portfolios, margin calls, Equity Derivatives Markets, commodities, foreign exchange, global Interest Rate Reporting Repository, IRRR, eligible trades, Depository Trust & Clearing Corporation, DTCC, Warehouse Trust, zero coupon swaps, single currency basis swaps, forward rate agreements, cross-currency swaps, caps, floors, European swaptions, inflation swaps, default management, inter-dealer service, clearing house, Master Confirmation Agreement, MCA, European Interdealer Index Swap Annex, EMEA EM Options Annex, European Interdealer Fair Value Swap Annex, Roadmap for Collateral Management, Dispute Resolution Procedure, DRP, Market Review of Collateralization, Feasibility Study for Extending Collateralized Portfolio Reconciliations, Implemenation Plan for Wider Market Roll-out, central settlement, settlement automation, Interoperability, trade date matching, novation consent process, Electronically Eligible Products, Confirmable LIfecycle Events, electronic confirmation targest, submission timeliness, matching, confirmation backlog reduction, cash flow matching, rates allocation commitment, electronic allocation delivery functionality, Allocation Industry Working Group,

Comment Letter to Department of Treasury on Issues Regarding the Treatment of OTC Derivatives in Bankruptcy and Under a Resolution Authority Framework02.12.10

MFA submitted a letter to Treasury Deputy Secretary Neal Wolin, which set out several issues related to the treatment of […]

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Topics: derivatives contracts liquidation event, over-the-counter derviatives, OTC derivatives, central clearing, bankruptcy, reolution authority framework, collateral, clearing member, central counterparty provider, CCP, hedge fund, segregation, initial margin, Dealer, customer position, insolvency, credit default swap, CDS, Federal Reserve Bank of New York, Europe, Report to the Supervisors of the Major OTC Derivatives Dealers on the Proposals of Centralized CDS Clearing Solutions for the Segregation and Portability of Customers CDS Positions and Related Margin, Cleary Report, U.S. commodity laws, futures clearing merchants, FCM, portability, commodity contracts, Commodity Futures Trading Commission, CFTC, swap dealer, broker-dealer, Automatic Stay, Qualified Financial Contract, swap agreement, termination value, transfer obligation, Walkaway Clauses, bankruptcy trustee, resolution authority receiver, limitation period, look-back period, preferential transfers,

MFA Comment Letters

Topic: portability