MFA Comment Letters

Topic: SIFMA

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 […]

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 Files Amicus in Lehman Litigation to Support Judicial Asset Sale Process09.28.12


MFA filed an amicus brief in the Barclays Capital and LBI SIPA Trustee litigation before the Second Circuit Court of […]

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Topics: Acton v. Fullmer (In re Fullmer) Adam Levitin, Adelphia Recovery Trust v. HSBC Bank USA (in re Adelphia Recovery Trust), alternative investment industry, amicus brief, amicus curiae, Asia, assets under management, AUM, Australia, bankruptcy, Bankruptcy Code, bankruptcy court, banks, Barclays Capital, Bass v. Parsons (In re Parsons), best practices, Big Shanty Land Corp. v. Comer Props. Inc., borrowers, capital markets, Clarification Letter, contract, debtor, Ella Shenhav, endowments, Europe, Financier Worldwide, Folger Adam Security Inc. v. Dematteis/MacGregor, free and clear, Harvey Miller, Illinois, In re Cavalieri, In re Cedar Tide Corp, In re F.A. Potts & Co., In re Fehl, In re Gulf Coast Oil Corp., In re Integrated Res. Inc., In re Sapolin Paints Inc., In re Savage Indus. Inc., In re Silver Bros. Co., In re Smith, In re Weisser Eyecare Inc., institutional investors, interest rates, James W. Giddens, Kelly DePonte, LBHI, Lehman Brothers Holding Inc., Lehman Margin Cash, lenders, liquidity, litigant, Lori Fife, M.R.R. Traders Inc. v. Cave Atlantique, Managed Funds Association, Matter of Pease, Med. Malpractice Ins. Ass'n v. Hirsch (In re Lavigne), Meinwald v. Meinwald, MFA, Morgan Olson LLC v. Federico et al. (In re Grumman Olson Indus. Inc.), New York Adelphia, no-cash deal, pensions, public policy, purchaser, Richard Mikels, risk management, Rob Copeland, secondary offerings, Securities Investor Protection Corporation Trustee, SIFMA, stakeholders, transparency, U.S. Court of Appeals for the Second Circuit, United States Bankruptcy Court for the Southern District of New York, United States v. Sforza, Walker v. Lee (in re Rounds), Winston Inn & Rest. Corp. v. DeMichiel (In re Winston Inn & Rest. Corp.),

MFA Submits Amicus Brief on Issue of Creditor Coordination06.29.12


On June 29, MFA filed an amicus brief in the 11th Circuit en banc review of the CompuCredit case.  At […]

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Topics: Aidan Synnott Ali Stoeppelwerth, alternative investment industry, anticompetitive, Arizona v. Maricopa County Medical Society, Bankruptcy Code, Bankruptcy Filing, banks, bilateral monopoly, Board of Governors of the Federal Reserve System, Bondholder, bonds, borrowers, Brendy Kuehne, Broad. Music Inc. v. Columbia Broadcasting Sys. Inc, broker-dealer, Bus. Elecs. Corp. v. Sharp Elecs. Corp., capital, capital formation, chilling effect, Classic Cheesecake Co. Inc. v. JPMorgan Chase Bank NA, collective action risks, competition, Compucredit Holdings Corporation v. Akanthos Capital Management LLC, Conrad Duberstein, contract, contractual relationship, corporate bonds, credit market, credit squeeze, creditor, creditor coordination, Daniel Crane, debt instruments, debtor, distressed debt, Edward Altman, Falstaff Brewing Corp. v. New York Life Ins. Co., FDIC, Federal Deposit Insurance Corporation, Federal Trade Commission v. Brown Shoe Co., Federal Trade Commission v. Indiana Federation of Dentists, Federal Trade Commission v. Superior Court Trial Lawyers Association, Financial Crisis Inquiry Commission, Finnegan v. Campeau Corp., Glenn Merrick, hedge funds, high-velocity market, institutional lender, interest rates, investment banks, Ireland v. Craggs, John Coffee Jr., Judge Easterbrook, Leegin Creative Leather Products Inc. v. PSKS Inc., leverage, Loan Syndications and Trading Association, low-velocity market, Marcel Kahan, Maris Distrib. Co. v. Anheuser-Busch Inc., market power, maturity date, Michael MacKenzie, Moses Silverman, National Collegiate Athletic Association v. Board of Regents, New York University Salomon Center, Nicole Bullock, Northwest Wholesale Stationers Inc. v. Pacific Stationery & Printing Co., Office of the Comptroller of the Currency, Palmyra Park Hosp. Inc. v. Phoebe Putney Memorial Hospital, par value, per se rules, pre-packaged bankruptcy, price competition, price-fixing, primary market, Reisner v. General Motors Corp., Reiter v. Sonotone Corp., risk portfolio, secondary loan markets, securities firms, Securities Industry and Financial Markets Association, Shared National Credit Review, Sharon Steel Corp. v. Chase Manhattan Bank NA, SIFMA, Smith v. The Ferncliff, State Farm Mutual Auto. Ins. Co. v. Physicians Injury Care Center Inc., Stern School of Business, syndicated loan market, systemic risk, Tomotaka Fujita, Twin City Pipe Line Co. v. Harding Glass Co., U.S. Court of Appeals for the Eleventh Circuit, U.S. Court of Appeals for the Second Circuit, U.S. Court of Appeals for the Seventh Circuit, Unijax Inc. v. Champion International Inc., United Airlines Inc. v. U.S. Bank NA, United States v. Giordano, United States v. Topco Assocs Inc., Volt Info. Scis. Inc. v. Board of Trs. of Leland Stanford Jr. University, William Klein,

Comment Letter to the CFTC on its Proposed Core Principles and Other Requirements for Swap Execution Facilities03.08.11


MFA submitted a comment letter to the CFTC on its proposed Core Principles and Other Requirements for Swap Execution Facilities. […]

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Topics: annual review auction-based methods, available for trading, bilateral trading, bilateral trading environment, block size, block trade thresholds, block trades, cash position, CBOE futures exchange, CEA, central limit order variants, CFTC, chief compliance officer, cleared swaps, Commodity Futures Trading Commission, competition, complete audit trail, conflicts of interest, congestion, connectivity, credit default swaps, crossing, daily trading records requirements, data analysis, DCM, dealer-to-customer platforms, debt instrument, Designated Contract Market, discreet contract, electronic platform, emergency procedure, exchanges, exchanges for physical, exchanges for swaps, execution protocol, fixing, flexibility, futures position, grace period, grandfather relief, institutional investors, interstate commerce, ISDA, joint the trade, large notional transaction size threshold, limit order, linked transactions, liquidity, liquidity characteristics, major swap participants, Mandatory Execution Requirement, mandatory minimum required recipients, mandatory objective criteria, mandatory transparent criteria, Manipulation, market efficiencies, market liquidity, market-based competition, matching, matching traders, minimum block sizes, minimum block threshold, multiple-to-multiple trading venues, non-continuous liquidity, off-market transactions, one-to-one voice services, open outcry trading pits, order book, order book systems, OTC, OTC market, Over-the-Counter, Over-the-Counter Derivatives Markets, packaged transactions, permitted transactions, physical contract, physical position, price distortion, public information, quote requesters, quote-requesting participant, real-time public reporting of swap transaction data, recordkeeping requirements, regulatory efficiencies, reporting requirements, request for quote, required transactions, responsive quote, resting bids, RFQ, RFQ response period, RFQ system, Rulebook, SB SEF, security-based swap execution facility, SEF trading platforms, SEFs, SIFMA, single joint transactions, sporadic liquidity, swap data repositories, swap execution, swap execution facilities, timing delay, trading venues, transparency, voice-based system, voice-based trading, widened bid/offer spreads,
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