MFA Comment Letters

Topic: Security-Based Swap Dealer

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 […]

MFA and AIMA Submit Joint Letter on CPSS-IOSCO Consultative Report on Financial Market Infrastructure Recovery10.11.13


MFA and AIMA submitted a joint letter to the Committee of Payment and Settlement Systems (CPSS) and the International Organisation […]

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Topics: AIMA Alternative Investment Management Association, bail-in, Bank for International Settlements, Bank for International Settlements Committee on Payments, bankruptcy, broker-dealer, buy-side firms, capital requirements, CCP, central counterparty, CFTC, clearing, clearing member, collateral, Commodity Futures Trading Commission, competition, conflict of interest, consultation paper, contagion, default, default management committees, default waterfall, Dodd-Frank Act, EMIR, ESMA, European Securities and Markets Authority, European Union, ex ante measures, exchange-traded, exchange-traded derivatives, financial stability, financial system, G20, haircuts, hedge, initial margin, International Organization of Securities Commissions, IOSCO, liquidity, majory security-based swap participant, mandatory clearing, margin, margin haircut, mark-to-market, market infrastructures, market participants, orderly liquidation, OTC derivatives, over-the-counter derivatives, physical commodity, portfolio, prudential regulators, regulatory framework, risk committees, risk management, security arragements, security-based swap clearing agencies, Security-Based Swap Dealer, security-based swap execution facility, sell-side firms, shareholders, stress-testing methodologies, systemic risk, systemically important financial market infrastructure, title transfer collateral arrangements, trading venues, trading volume, transparency, uncleared derivative, Unwind, variation margin,

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: "too big to fail \, 111th Congress, accounting, AIG, American International Group, asset class, asymmetrical initial margin exchange, asymmetry, bankruptcy, bankruptcy estate, Bart Chilton, Basel Committee on Banking Supervision, Ben Bernanke, best practices, bilateral exchange of variation margin, Broker, broker-dealer, buy-side firms, capital, capital charge, capital formation, capital inefficiency, capital requirements, Cash Flow, CCP, CDS, central clearing, central counterparty, CFTC, Chicago Mercantile Exchange Holdings Inc., Chicago Trading Company, collateral, collateral management, collateral management stystems, commodity broker, Commodity Futures Trading Commission, complexity, compliance, compliance date, Council of the European Union, counterparties, counterparty risk, credit default swap, credit risk, creditworthiness, cross-margining, cross-product master netting agreements, customer collateral, customer protection, customer replicability, customized risk management tools, Darrell Duffie, DCO, Dealer, dealers, default, default segregation model, derivatives, derivatives clearing organization, Division of Clearing and Intermediary Oversight, Dodd-Frank Act, efficiency, eligible collateral, endowments, enhanced protections, Eric Chern, European Commission, European Parliament, federal register, Federal Reserve Bank of New York, Federal Reserve Bank of New York Staff Report No. 424, Federal Reserve Board, fellow customer risk, financial contagion, financial crisis, Financial Industry Regulatory Authority, financial institutions, financial instrument, financial system, FINRA, forwards, Fraud, haircuts, hedge funds, House Committee on Financial Services, ICE Clear Europe Limited, ICI, independent third party custodian, Individual Segregation, initial margin, insolvency, international harmonization of regulations, International Organization of Securities Commissions, international regulatory standards, Investment Company Institute, investment risk, Investor Protection, IOSCO, ISDA, ISDA Margin Survey 2012, LCH.Clearnet Ltd., legal segregation with operation commingling, Lehman Brothers, leverage, liquidation, liquidation time horizon, liquidity, LSOC, Major Security-Based Swap Participant, Major Swap Participant, mandatory clearing, margin, margin requirements, margining, market participants, market practice, market risk, MF Global Inc., money market instruments, multiplier, netting, New York Portfolio Clearing LLC, non-commercial end-users, Notice of Exclusive Control, omnibus segregation, operational and legal commingling, operational costs, operational risk, Options Clearing Corporation, OTC derivatives, out-of-the-money, pension, Peregrine Financial Group, portability, portfolio compression, portfolio margining, portfolio reconciliation, Private Funds Managers, pro-cyclical effects, product type, proprietary information, prudential regulators, reconciliation, reform, registered clearing agencies, regulation, regulatory arbitrage, repurchase agreements, risk, risk management, Robert Wasserman, Russell Wasendorf, SEC, securities, Securities and Exchange Commission, Securities Industry and Financial Markets Association, Security-Based Swap Dealer, Security-Based Swap Transactions, security-based swaps, segregation, segregation model, sell-side firms, settlement, settlement risk, SIFMA, state and federal laws, state bank regulator, swap dealer, swap dealers, Swap Trading Relationship Documentation, systemic risk, tentative net capital, third-party custody arrangement, too interconnected to fail, trade repositories, trading costs, transparency, tri-party custodial arrangements, two-way margining, U.S. dollar, university endowment, Value at Risk, VaR, variation margin, White Paper, Working Group on Margining Requirements,

MFA Submits Accompanying Portfolio Margining Letter11.26.12


MFA submitted a supplemental comment letter to the U.S. prudential regulators during the reopened comment period for their proposed rulemaking […]

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Topics: affiliate-held collateral bankruptcy, Board of Governors of the Federal Reserve System, broker-dealer, buy-side, capital markets, capital requirements, caps, CCP, CDS, central counterparties, CFTC, Chevron Products Co. v. SemCrude L.P., Chicago mercantile exchange, Cleared Products, CME Clearport, CME Group, collateral, Collecting Futures Commission Merchant, commodity broker, Commodity Futures Trading Commission, covered swap entities, covered swap entity, credit default swap, cross-currency swaps, cross-margining, Dealer, debt obligation, Depositing Futures Commission Merchant, derivatives clearing organization, Dodd-Frank Act, eligible collateral, end-users, Farm Credit Administration, Farm Credit System, FCM, FDIC, Federal Agricultural Mortgage Corporation, Federal Deposit Insurance Corporation, Federal Home Loan Banks, Federal Home Loan Mortgage Corporation, Federal Housing Finance Agency, Federal National Mortgage Association, floors, futures, futures commission merchant, hedging, ICE Clear Credit, ICE Clear Europe, In re Lehman Brothers Holdings Inc et al, index CDS, inflation swaps, initial margin, insured obligation, LCH.Clearnet Ltd., liquidity, Major Security-Based Swap Participant, Major Swap Participant, mandatory clearing, margin, market liquidity, market participants, master netting agreements, New York Portfolio Clearing LLC, Office of the Comptroller of the Currency, options, Options Clearing Corporation, OTC derivatives, over-the-counter derivatives, portfolio margining, posted margin, prudential regulators, redundant margin, regulatory regime, risk, SEC, Securities and Exchange Commission, Security-Based Swap Dealer, security-based swaps, segmentation, swap dealer, swaps, swaptions, systemic risk, triangular setoff, uncleared swaps,
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