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MFA Comment Letters

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Topic: regulatory

MFA Comment Letter to the Committee of European Securities Regulators in Response to its Call for Evidence on Mutual Recognition with Non-European Union Jurisdictions09.04.09


MFA submitted a letter to the Committee of European Securities Regulators today in response to its Call for Evidence on mutual […]

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Topics: Committee of European Securities Regulators CESR, call for evidence, financial market, regulatory, trading venues, intermediaries, products, collective investment schemes, centralized counterparties, CCPs, over-the-counter derivatives, OTC, hedge funds, institutional investors, liquidity, price discovery, capital markets, Pension Funds, alternative investment funds, portfolio investment risk, market volatility, pricing efficiency, Internaional Organization of Securities Commissions, IOSCO, European Union, EU, U.S. Treasury Assistant Secretary for International Monetary and Financial Policy, Mark Sobel, spillovers, arbitrage, direct electronic access, DEA, short selling, Financial Stability Board, FSB, derivative sexchanges, credit default swaps, CDS, European Commission, EC, CFTC, SEC, Federal Reserve Board, CCP, European Forum of Deposit Insurers, Federation Bancaire Francaise, transparency, industry best practices, systemic risk, de minimis, assets under management, AUM, EC's Proposal for a Directive of the European Parliament and of the Council on Alternative Investment Fund managers, European Parliament, Securities and Exchange Commission, Commodity Futures Trading Commission, Federal Reserve Bank of New York, G20,

MFA Comments to SEC on Proposed Short Selling Restrictions06.22.09


MFA submitted a letter to the SEC in response to its request for comments on proposed short sale restrictions. MFA […]

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Topics: Securities and Exchange Commission SEC, Regulation SHO, Reg SHO, Release, short selling, price test, market-wide, short sale price test, single security circuit breaker, investors, issuers, legislators, stock price, investor confidence, uptick rule, public comment, private investment pools, pensions, endowments, foundations, volatility, securities, empirical data, capital formation, market liquidity, price discovery, pricing efficiency, price test limitations, public interest, cacpital, transaction costs, circuit breaker, regulatory, antifraud authority, shares, SEC Office of Economic Analysis, OEA, floor brokers, high frequency, buy-side firms, hedged, broker dealers, pre-borrow requirement, arbitrage, T+4 close-out, Division of Trading and Markets, solvency, G19, Hong Kong, public disclosure, retail, Nasdaq bid test, bear raids, Credit Suisse, Russell 3000, full sample period, Internet, airline, Barra, preferred security, convertibles, interest list, locate numbers, custodian, T+3, merger arbitrage, event-driven investing, warrants, index products, merger, acquisition, exchange offer, spin-off, split-off, recapitalization, ETFs,

MFA Letter to FTC on Prohibition of Energy Market Manipulation Rule05.20.09


MFA jointly with FIA, CME Group, ICE and NFA submitted a letter to the Federal Trade Commission regarding its “Prohibition […]

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Topics: Federal Trade Commission FTC, Market Manipulation Rulemaking, futures group, Part 317, anti-manipulation protections, non-futures, wholesale markets, crude oil, gasoline, commodities, Manipulation, fraud proscriptions, Commodity Futures Trade Commission, CFTC, petroleum distillates, exclusive jurisidiction provision, safe harbor, federal register, exclusive jurisdiction provision, price discovery, forward market business activities, regulatory, CEA, anti-manipulation system, false reports, commodity prices, resource limitations, congressional grant, energy markets, John M. Damgard, Futures Industry Association, FIA, Jerrold E. Salzman, CME Group Inc., Thomas W. Sexton, National Futures Association, NFA, Jeffrey Sprecher, IntercontinentalExchange, ICE, Donald S. Clark, Advanced Notice of Proposed Rulemaking, wholesale purchase, options trading, energy futures, futures exchange, Chciago Mercantile Exchange Inc., Board of Trade of the City of Chicago, Inc., CBOT, new York Mercantile Exchange Inc., NYMEX, Commodity Exchange, COMEX, ICE Futures U.S., New York Board of Trade, ICE Futures of Europe, ICE Futures Canada, Winnipeg Commodity Exchange, over-the-counter energy trading platform, commercial market, limited-purpose national securities association, customer protection, merchants, brokers, commodity pool operators, commodity trading advisors, registered account executives, sugar, corn, ethanol, price effects requirements, compliance burden, U.S. Court of Appeals for the Seventh Circuit, Board of Trade of City of Chicago v. SEC, 677 F.2d 1137 (7th Cir. 1982), Chicago Mercantile Exch. v. SEC, 883 F.2d 537 (7th Cir. 1989), Board of Trade of City of Chicago v. SEC 677 F.2d 1137, 1145 (7th Cir. 1982), FTC v. Roberts, 276 F.3d 583 (D.C. Cir. 2001), 276 F.3d at 592, chain of precedent, 276 F.3d at 591, SEC vs. Hopper, corporate disclosures, US vs. Reliant Energy Services, 420 F Supp.2d 1043 (N.D. Cal. 2006), exclusive regulatory authority, Federal Energy Regulatory Commission, FERC, instruments, accounts, Ken Roberts Co. v. FTC, No. 01-1772, 537 U.S. 820, 2002 WL 32135703, speculative limits, Energy Department, DOE, Environmental Protection Agency, EPA, emissions credit, Agriculture Department, USDA, Williamson v. United States, 512 U.S. 594, Trichilo v. Sec'y of Health & Human Servs., 823 F.2d 702, 706 (2d Cir. 1987), SEC v. American Commodity Exch., 546 F.2d 1361, International Trading Ltd. v. Bell, 556 S.W.2d 420 (Ark. 1977), Clayton Brokerage Co. v. Mouer, 531 S.W.2d 805 (Tex. 1975), Minnesota v. Coin Wholesalers, 250 N.W.2d 583 (Minn. 1976), Amaranth, statutory authority, non-petroleum based commodities, agricultural feed-stocks, price artificiality, contract markets, intermediaries, agents, counterparties, contractual privity, contradictory requirements, United States Congress, 2006 WL 778640 (S.D. Tex. March 24 2006),
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