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MFA Comment Letters

› Issues & Policy

Topic: stability

Comment Letter to SEC on FINRA Rulemakings Regarding the Imposition of Trading Halts by SROs10.25.11


MFA filed a comment letter with the SEC in response to coordinated rule proposals from FINRA and other SROs that […]

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Topics: Securities and Exchange Commission SEC, self-regulatory organization, Financial Industry Regulatory Authority, SROs, trading halts, Market-Wide Circuit Breakers, Joint Commodity Futures Trading Commission-SEC Advisory Committee on Emerging Regulatory Issues, securities, Dow Jones Industrial Average, S&P 50 Index, benchmark index, percentage declines, Level 1 Declines, Level 2 Declines, Level 3 Declines, primary listing market opens, trading day, stability,

Letter to European Commissioner Olli Rehn on EU Competent Authorities Restricting or Banning Short Selling08.14.11


MFA submitted letters to EU policymakers and market authorities on the decision by certain market authorities to restrict short selling. […]

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Topics: Olli Rehn European Commissioner for Economic and Monetary Affairs, European Commission, Belgium, bans on short-selling, investor, confidence, market stability, short sale restrictions, short sale ban, volatility, manage risk, raise capital, convertible bond, convertible preferred security issuances, convertible products, hedge the risk, short sales, consultation period, compliance efforts, Securities and Exchange Commission, SEC, capital raising, market efficiency, trading volume, market liquidity, bid-ask spreads, short selling bans, bona fide hedging strategies, risk management, capital formation, purchasing overall, institutional investors, illiquid positions, option value, G19 securities, long sellers, contrarian traders, ESMA, certainty, public consultation, futures, broad-based indices, stability, hedge funds, Richard H. Baker,

Letter to the European Council on EU Competent Authorities Restricting or Banning Short Selling08.14.11


MFA submitted letters to EU policymakers and market authorities on the decision by certain market authorities to restrict short selling. […]

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Topics: Herman Van Rompuy President of the European Council, bans on short-selling, investor confidence, market stability, short sale restrictions, volatility, manage risk, raise capital, convertible bond, convertible preferred security issuances, convertible products, hedge the risk, consultation period, compliance efforts, Securities and Exchange Commission, SEC, capital raising, market efficiency, decreased trading volume, market liquidity, bid-ask spreads, short selling bans, bona fide hedging strategies, risk management, short sales, short selling, risk-management, capital formation, purchasing, institutional investors, illiquid, option value, G19 securities, long sellers, contrarian traders, ESMA, certainty, public consultation, broad-based indices, futures, stability, hedge funds, Richard H. Baker, Belgium,

Letter to the European Central Bank on EU Competent Authorities Restricting or Banning Short Selling08.14.11


MFA submitted letters to EU policymakers and market authorities on the decision by certain market authorities to restrict short selling. […]

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Topics: Jean-Claude Trichet European Central Bank, Germany, bans on short-selling, investor confidence, market stability, volatility, manage risk, raise capital, convertible bond, convertible preferred security issuances, convertible products, hedge the risk, Securities and Exchange Commission, SEC, capital raising, market efficiency, trading volume, market liquidity, bid-ask spreads, short selling bans, bona fide hedging strategies, risk management, short sales, short selling, risk-management, capital formation, purchasing, institutional investors, illiquid, option value, G19 securities, long sellers, contrarian traders, ESMA, certainty, public consultation, futures, broad-based indicies, stability, hedge funds, Richard H. Baker,

Letter to European Commissioner Michel Barnier on EU Competent Authorities Restricting or Banning Short Selling08.14.11


MFA submitted letters to EU policymakers and market authorities on the decision by certain market authorities to restrict short selling. […]

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Topics: Belgium bans on short-selling, investor confidence, market stability, short sale restrictions, volatility, manage risk, raise capital, convertible bond, convertible preferred security issuances, convertible products, hedge the risk, consultation period, compliance efforts, Securities and Exchange Commission, SEC, capital raising, market efficiency, trading volume, market liquidity, bid-ask spreads, short selling bans, bona fide hedging strategies, risk management, short sales, short selling, risk-management, capital formation, purchasing, institutional investors, illiquid, option value, G19 securities, long sellers, contrarian traders, ESMA, certainty, public consultation, futures, broad-based indices, stability, hedge funds, Richard H. Baker,

Letter to ESMA on EU Competent Authorities and ESMA Restricting or Banning Short Selling08.14.11


MFA submitted letters to EU policymakers and market authorities on the decision by certain market authorities to restrict short selling. […]

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Topics: France bans on short-selling, investor confidence, market stability, short sale restrictions, volatility, manage risk, raise capital, convertible bond, convertible preferred security issuances, convertible products, hedge the risk, consultation period, compliance efforts, Securities and Exchange Commission, SEC, capital raising, market efficiency, decreased trading volume, market liquidity, bid-ask spreads, short selling bans, bona fide hedging strategies, risk management, short sales, short selling, risk-management, capital formation, purchasing, institutional investors, illiquid, option value, G19 securities, long sellers, contrarian traders, ESMA, certainty, public consultation, futures, broad-based indices, stability, hedge funds, Richard H. Baker,

Letter to France’s AMF on Competent Authorities Restricting or Banning Short Selling08.13.11


MFA submitted letters to EU policymakers and market authorities on the decision by certain market authorities to restrict short selling. […]

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Topics: France Autorite des Marches Financiers, AMF, bans on short-selling, investor confidence, market stability, short sale restrictions, volatility, manage risk, raise capital, convertible bond, convertible preferred security issuances, convertible products, hedge the risk, consultation period, compliance efforts, Securities and Exchange Commission, SEC, capital raising, market efficiency, market liquidity, bid-ask spreads, short selling bans, bona fide hedging strategies, risk management, short sales, short selling, risk-management, capital formation, institutional investors, illiquid, option value, G19 securities, long sellers, contrarian traders, ESMA, certainty, public consultation, futures, broad-based indices, stability, hedge funds, Richard H. Baker,

MFA Response to CESR Consultation Paper on a Proposal for a Pan-European Short Selling Disclosure Regime10.01.09


MFA submitted a letter to the Committee of European Securities Regulators (CESR) today in response to its Consultation Paper on a […]

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Topics: Committee of European Securities Regulators CESR, CESR Proposal for a Pan-European Short Selling Disclosure Regime, alternative investment managers, hedge funds, fund of funds, hybrid funds, 130/30 funds, managed futures funds, industry service providers, alternative investment industry, absolute return strategies, short selling, manipulative conduct, Market Confidence, stability, public disclosure of short positions, short positions, market volatility, price discovery, risk management, risk management function, significant adverse effect, financial services sector, investors, Issuer, market participants, de minimis, aggregated anonymised data, timeframe for reporting, transparency directive, meaningful data, short selling bans, global equity markets, academics, liquidity, bid-ask spread, price declines, materially negative impacts, market efficiency, short selling disclosure regime, equity markets, enhanced transparency, investment managers, abusive short selling practices, abusive practices, financial institutions, herding, institutional investors, retail investors, transaction costs, capital markets, free flow of information, chilling effect, alternative investment classes, Pension Funds, endowments, foundations, alternative investment vehicles, hedging strategies, capital formation, hedge, convertible arbitrage, short equity position, convertible bonds, traditional bond issuance, convertible securities, short squeeze, Reverse Engineered, trading strategies, long equity positions, exposures, Unwind, financial stocks, pricing efficiency, short selling prohibitions, European markets, large-scale short selling, extreme market conditions, negative returns, UK Financial Services Authority, FSA, securities prices, naked short selling, Journal of Finance, Credit Suisse, market stability, disclosure thresholds, private reporting, flagging short sales, Financial Regulatory Authority, FINRA, flagging regime, disproportionate costs, real time information, over-the-counter transactions, exchanges, trading platform, settlement, physical short sales transactions, EEA stock, extraterritoriality, European Union, EU, EEA equities, two-tier disclosure model, price amplification, market testing, MiFID, competent authorities, Member State competent authorities, professional secrecy, confidentiality, freedom of information regimes, harmonization, net economic short positions, transitory short position, abusive behavior, share issues, capital raising, index trading, basket trade, reporting regimes, net economic short position, asset management company, aggregation, prudential regulators, T+1 reporting, derivatives, derivative positions, delta adjusted, cumulative compliance costs, global capital markets, EU Member State, market maker, market making,

MFA Comments in Response to the IOSCO Consultation Report on Hedge Funds Oversight04.30.09


MFA submitted a written response to the IOSCO Consultation Report on Hedge Funds Oversight. MFA’s comments focused on four key […]

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Topics: Technical Committee of the Internationl Organization of Securities Comissions IOSCO, Hedge Funds Oversight: Consulation Report, global crisis, investor confidence, capital markets, Market Confidence, stability, hedge funds, systemic risk, market integrity, Investor Protection, regulation, private pools, capital, Task Force on Unregulated Financial Entities, standardized disclosures, minimum capital requirements, liquidity, price efficiency, global integration, counter-cyclical force, buyers, distressed assets, sellers, selling short, equities, pension plans, endowments, European Commission, EC, alternative investment fund managers, prime brokers, residential mortgage lending, Lehman Brothers, mutual fund, banking, Financial Research Corp. counterparties, Long Term Capital Management, Lord Adair Turner, U.K. Financial Services Authority, FSA, diligence process, Anti-Fraud Provisions, securities laws, transparency, customer collateral, performance compensation, advisory relationships, high-water mark, management fee, insider trading, MFA's Sound Practices for Hedge Fund Managers, over-the-counter derivatives, credit default swaps, CDS, absolute return, Operations Management Group, OMG, Commission Bancaire of France, bilateral solutions, business-process objectives, Fannie Mae, Freddie Mac, equity derivative confirmations, centralized clearing, clearinghouse platforms, President's Working Group's Asset Managers' Committee, Alternative Investment Management Association, Hedge Fund Standards Board, Financial Stability Forum, best practices, public disclosure, proprietary information, moral hazards, orderly dissolution, Rulemaking, G-20, OTC derivatives, Federal Reserve Bank of New York,

MFA Comments on Best Practices Reports Released by Two Committees Appointed by U.S. President’s Working Group on Financial Markets06.13.08


MFA submitted comments on the Best Practices Reports released by the two Committees appointed by the U.S. President’s Working Group […]

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Topics: Report of the Asset Managers' Committee of the President's Working Group on Financial Markets President's Working Group on Financial Markets, Best Practices for the Hedge Fund Industry, Alternative Investment Management Association, AIMA, business continuity, disaster recovery, anti-money laundering, compliance, risk management, operational systems, due diligence, stability, integrity, managers, investors, counterparties, Regulators, diligence, counterparty disclosure, Disclosure, Investor Protection, mandates, Counterparty Risk Management Policy Group, CRMPG, private placement memorandum, PPM, risk exposure, leverage, valuation hierarchy, OTC, Over-the-Counter, parallel managed account, valuation committee, third party administrator,