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MFA Comment Letters

› Issues & Policy

Topic: SEC

Joint Letter on SEC Concept Release09.24.19


On September 24, MFA submitted a joint letter with AIMA in response to the SEC’s Concept Release on Harmonization of […]

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Topics: harmonization SEC, SEC concept Release, investment adviser,

MFA Joint Petition on SIP Transparency09.17.19


On September 17, MFA, SIFMA, ICI, CII and several individual firms submitted a petition to the SEC regarding governance by […]

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Topics: SEC SIP, market data,

MFA Comments on SEC Proposed Fund of Funds Arrangements04.30.19


On April 30, MFA submitted a letter to the SEC in response to its proposal to update the regulatory framework […]

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Topics: SEC 12d1-4,

MFA Submits Letter to SEC on Proposed Cross-Border Application of its Rules to Non-U.S. Persons07.13.15


MFA submitted a letter to the Securities and Exchange Commission (SEC) on its proposed rules on “proposed rules on “Application […]

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Topics: SEC Cross-Border, CFTC, prudential regulators, SBS,

MFA Comment Letter on SEC’s Proposed Rules under 12(g) of the Exchange Act03.06.15


On March 2, MFA submitted a comment letter in response to the Securities and Exchange Commission’s proposed rules to implement […]

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Topics: JOBS Act SEC, 12(g), Exchange Act,

MFA Writes SEC on Tick Test Pilot Program12.22.14


On December 22, 2014, MFA filed a comment letter to the SEC on the agency’s proposed Tick Test pilot program.  MFA also referenced […]

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Topics: SEC tick test,

MFA Comment Letter to Prudential Regulators on Final Margin Requirements11.25.14


On November 24, MFA submitted a comment letter to the U.S. Prudential Regulators (Fed, FDIC, OCC, FCA and FHFA) to […]

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Topics: margin Regulators, FDIC, Fed, OCC, FCA, FHFA, swaps, EMNA, initial margin, BASEL, IOSCO, CFTC, SEC, Cross-Border,

MFA, ICI & SIFMA Order Routing Disclosure Template Recommendation to SEC10.23.14


On October 23, MFA, ICI and SIFMA submitted a letter and order routing disclosure template to Chair White for the […]

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Topics: ICI SIFMA, routing disclosure, SEC, Broker, institutional investors,

MFA Submits Request for No-Action Relief to CFTC on Package Transactions10.15.14


MFA submitted a request for no-action relief to the CFTC for the three categories of package transactions for which relief from the […]

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Topics: CFTC package transactions, SEF, swap execution facilities, Division of Market Oversight, DMO, Commodity Futures Trading Commission, Request for Relief, Trade Execution Requirement, Package Transaction, No-Action Letter 14-62, Division of Clearing and Risk, SEFs, designated contract markets, DCMs, derivatives clearing organizations, DCOs, future commission merchants, FCMs, No-Action Letter No. 14-21, facilitating trade execution, off-SEF, NAL 14-62, MAT, Non-MAT, request for quote, RFQ, International Swaps and Derivatives Association, ISDA, dealer-to-dealer, mortgage-backed security, MBS, invoice spreads, cash/futures basis packages, central limit order book, CLOB, non-USD swap spread, index CDS, single-name CDS, SEC,

MFA Submits Letter to UK FCA in Response to Discussion Paper on Dealing Commissions10.10.14


MFA submitted a letter to the UK FCA in response to its Discussion Paper on the use of dealing commissions. […]

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Topics: Wholesale Conduct Policy Team Financial Conduct Authority, ESMA, MiFID, MiFID II Level 2, unbundling, FCA, DP14/3, CP13/17, Oxford Economic Research Associates, OXERA, VAT, hard dollar, soft dollar, broker-dealer, sell side, Securites and Exchange Commission, SEC, UCITS, Directive and the Alternative Investment Fund Managers Directive,
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