MFA Comment Letters

Topic: Securities and Futures Commission

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: aggregation AIMA, alpha swap, alternative investment funds, Alternative Investment Management Association, alternative investment strategies, anonymity, Asset Management Group of the Securities Industry and Financial Markets Association, assets under management, AUM, Bankruptcy Code, benchmark contracts, bespoke swaps, beta swap, board of directors, British Virgin Islands Financial Services Commission, burdensome, buy-side, cash-settled contracts, Cayman Islands, Cayman Islands Monetary Authority, CCP, central clearing, central counterparties, CFTC, chilling effect, cleared swaps, collateral, Committee of Payment and Settlement Systems, Commodity Futures Trading Commission, commodity interests, Commodity Markets Council, commodity pool, commodity pool operators, commodity trading advisors, compliance, corporations, CPO, CPO delegation, Cross-Border, CTA, custody rules, customer collateral, customer protection, DCM, DCO, Dealer, dealer-to-customer platforms, derivatives clearing organization, designated contract markets, Division of Market Oversight, Division of Swap Dealer and Intermediary Oversight, Dodd-Frank Act, due diligence, EFRPs, EMIR, EU, European Commission, European Union, exchange for related position, execution, exemptive relief, FCM, FCM counterparty, Financial Conduct Authority, financial counterparty, Financial Stability Board, floor brokers, Form CPO-PQR, Form CTA-PR, Form PF, Form PQR, FSB, Full Physical Segregation, fund of funds, futures commission merchant, GAAP, gamma swap, general partner, generally accepted accounting principles, gold, haircuts, harmonization, hedge fund, hedgers, Hong Kong, illiquid assets, initial margin, insolvency, inter-dealer market, interest rate markets, International Organization of Securities Commissions, International Swaps and Derivatives Association, introducing broker, invoice spreads, IOSCO, ISDA, J. Christopher Giancarlo, JOBS Act, legal segregation with operation commingling, limited liability companies, limited partnership, liquidity, loss allocation, LSOC, made available for trading, Major Swap Participant, mandatory clearing, Mark Wetjen, market infrastructures, market participant, master agreement, MAT, MF Global Inc., MSPs, National Futures Association, natural gas, NFA, no-action relief, Obama Administration, OTC derivatives, OTC Derivatives Regulators Group, owned entities, package transactions, passive ownership, Peregrine Financial Group, physically settled, Policy Makers, position limits, President Obama, price discovery, private equity fund, private funds, private investment funds, private investment vehicles, privately offered commodity pools, proprietary trading tools, public investment fund, quarterly account statements, real estate investment trust, recordkeeping requirements, registered investment adviser, regulation, regulatory framework, regulatory requirements, risk management, Scott O'Malia, SDR, SEC, Securities and Exchange Commission, Securities and Futures Commission, SEF, segregated account, service providers, Sharon Bowen, short, SIFMA AMG, silver, speculation, spot-month position limits, straight-through processing, swap butterflies, swap curves, swap data reporting, swap data repository, swap dealer, swap execution facilities, swaps, swaptions, systemic risk, temporary interim relief, third country, Timothy Massad, trading privileges, transparency, Trust, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, U.S. Congress, U.S. Department of the Treasury, U.S. person, United States, variation margin, Vincent A. McGonagle,

MFA Submits Comments on Hong Kong Consultation on Electronic Trading09.23.12


On September 23, MFA submitted comments to the Hong Kong Securities and Futures Commission on its consultation paper on the […]

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its “Proposed Interpretive Guidance […]

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Topics: accredited investors African Development Bank, AIMA, Alternative Investment Management Association, Asian Development Bank, banks, Business Conduct Standards, buy-side firms, CFTC, chief compliance officer, clearing, collective investment vehicles, comment letter, Commodity Futures Trading Commission, commodity pool, commodity pool operator, commodity swaps, compliance costs, Corporation, cost-benefit analysis, Council of the European Union, counterparties, CPO, CPO registration requirements, Dealer, dealers, Department of the Treasury, derivatives, derivatives markets, direct or indirect ownership, duplicative regulation, entity-level requirement, ESMA, estate, European Parliament, European Securities and Markets Authority, execution, fiduciary, financial crisis, financial stability, financial system, foreign banks, foreign entity, Form CPO-PQR, fund, fund of funds, G20, G20 commitments, general partnerships, hedge fund administrator, hedge fund industry, hedge fund managers, Hong Kong, Hong Kong Monetary Authority, income tax, Inter-American Development Bank, International Bank for Reconstruction and Development, international harmonization of regulations, International Monetary Fund, International Organization of Securities Commissions, interpretive guidance, IOSCO, Jill Sommers, joint-stock company, limited liability companies, listed entity, Look Through, major swap participants, majority ownership, margining, market impact, market participants, Monetary Authority of Singapore, MSPs, natural person, non-U.S. investment fund, non-U.S. market participants, non-U.S. persons, OTC derivatives, OTC derivatives market, over-the-counter derivatives, partnership, pension plans, Policy Makers, pooled accounts, portfolio reconciliation, prime brokers, qualified eligible person, real-time public reporting, registration, regulatory framework, regulatory requirements, reporting party, risk management, Scott O'Malia, SEC, Securities and Exchange Commission, Securities and Futures Commission, segregation, sell-side firms, shareholders, Singapore, substituted compliance, swap data recordkeeping, swap data reporting, swap data repository, swap dealer, swaps, swaps processing, third country, trade confirmations, transaction cost, transaction-level requirements, transparency, Trust, U.S. person, uncleared swaps, United Nations,

MFA Submits Comments to the Monetary Authority of Singapore on Proposed Regulations on OTC Derivatives03.26.12


MFA submitted a comment letter to the Monetary Authority of Singapore (MAS) in response to its Consultation Paper on Proposed […]

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Topics: aggregate counterparty credit risk average notional value, backloading, barriers to entry, bilateral market, buy-side clearing, CCP, central clearing, central counterparty, CFTC, clearing, clearing arrangements, clearing facilities, clearing house, clearing threshold, client access to clearing, commercial banks, Commodity Futures Trading Commission, confidentiality, Consultation Paper on Proposed Regulation of OTC Derivatives, counterparty identification, counterparty risk, customized and proprietary investment strategies, dealers, derivatives transactions, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, duplicative regulation, efficient capital flows, ESMA, EU, European Commission, European Union, financial entities, Financial Stability Board, foreign regulator, Form PF, fragmentation of liquidity, FSB, G20, G20 commitments, Gary Gensler, Honk Kong Monetary Authority, intellectual property, international harmonization of regulations, International Organization of Securities Commissions, IOSCO, legal entity identifiers, liquid and standardized transactions, liquidation horizons, mandary clearing, margin determinations, margin methodologies, margin requirements, market participants, Mary Schapiro, MAS, Monetary Authority of Singapore, money changers, netting, non-centrally cleared derivatives transactions, non-dealer client representation, non-financial entities, OTC derivatives, OTC derivatives market, over-the-counter derivatives, real-time processing, recognized clearing houses, registered insurers, regulatory regime, risk committees, risk management, Securities and Exchange Commission, Securities and Futures Commission, settlement risk, Singapore, straight-through processing, swaps, systemic risk, trade repositories, trading costs, trading mandate, transaction data, U.S. Federal Reserve Bank of New York, U.S. Senate Committee on Agriculture Nutrition and Forestry,

MFA Comments on Consultation on Increasing Short Position Transparency10.09.09


MFA submitted a letter to the Hong Kong Securities and Futures Commission (SFC) today in response to its Consultation Paper […]

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Topics: alternative investment classes anonymised disclosure, bid-ask spreads, capital formation, capital raising, cash markets, CESR, chilling effect, close out indicators, confidentiality, convertible arbitrage, convertible bonds, copycat behavior, delta adjusted, derivatives, designated securities, dual-listed securities, efficiency, endowments, exchange trading, Financial Services Authority, financial services sector, financial stocks, foundations, FSA, global equity markets, hedging strategies, herding, Hong Kong, Hong Kong market, institutional investors, investment managers, Journal of Finance, liquidity, listed corporations, manipulative conduct, market efficiency, market liquidity, market making, market participants, market volatility, net long position, net short positions, non-designated securities, non-public disclosure, off-exchange transaction, on-market transactions, OTC transaction, pan-European short selling disclosure regime, pensions, price discovery, price formation, price volatility, primary market, private reporting, proprietary research, public disclosure of short positions, reporting threshold, retail investors, risk management, SEC, Securities and Exchange Commission, Securities and Futures Commission, SEHK, settlement, SFC, short positions, short sellers, short selling, short selling bans, short selling disclosure regime, short squeeze, stocks, transaction costs, transitory short position, transparency, turnover ratio, volatility,
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