MFA Comment Letters

Topic: surveillance

Comment Letter to the CFTC in Response to its Request for Comments on Position Limits for Derivatives03.28.11


MFA submitted comments to the CFTC in response to its request for comments on position limits for derivatives. MFA remains […]

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Topics: account aggregation requirements active trading program, aggregate all-months-combined, aggregate single-month, aggregate spot-month position limits, agricultural commodities, agricultural model, annual limits, annual recalculation methodology, annual renewal based exemption, application based exemption, approval based exemption, arbitrage exemption, Artificial limits, asset manager, audit, Barclays Capital, Bauer College of Business, benchmark contracts, Berlin wheat, bona fide hedger, calendar-spread exemption, cash market risk, cash market transaction, cash position, cash-settled contracts, CBOT, CFTC, CFTC docket no. 08-02, CFTC docket no. 11-05, Chicago onions, class limits, cleared bilateral contracts, CME, commercial hedgers, commercial participants, Commission Energy Complex Report, Commodity Futures Trading Commission, commodity market, commodity pool operator, commodity trading advisor, commodity trading advisors, common parent, conditional-spot month limit, control standard, corporate enterprises, CPO, Credit Agricole, cross-ownership of traders, crowding out provision, crude oil futures, CTA, CTFC Inter-Agency Task Force on Commodity Markets, DCMs, deferred month positions, deliverable supply, delivery point, delta, derivatives, directional position, disaggregation relief, disclosure documents, disorderly markets, eligible entity, energy market infrastructure, energy price volatility, Energy Risk, enforcement, enumerated agricultural commodities, equity interest, excessive speculation, FCMs, federal limits, financial cal spread options, financial institution, forward position, front month position, funds of funds, future commission merchants, futures, futures class all-months-combined, futures class single-month, futures market, GAO, global commodity, Global Energy Management Institute, hedge funds, hedging transaction, HH natural gas, HM Treasury Global Commodities, House Committee on Agriculture, hypothetical portfolios, IMF World Economic outlook, IMG, independent account controller exemption, independent third party, independently controlled accounts, independently controlled and managed trader, index fund manager, individual class rules, inter-commodity spread exemption, inter-commodity spread transactions, interest rates, International Organization of Securities Commission, interstate commerce, IOSCO, IOSCO Technical Committee, Jacks Study, JP Morgan, KCBOT, large trader data, last day swaps, legacy position limits, liquid price discovery, liquidity provisions, long positions, market depth, market liquidity, market manipulation, market surveillance, metal commodity, no-action relief, non-cleared bilateral contracts, non-financial entity exemption, non-spot position limits, NYBOT, NYMEX crude oil price, NYMEX Henery Hub Natural Gas contract, OECD Food, OECD publishing, offsetting positions, open interest, open interest formula, operating company, option contract, options, order routing arrangement, OTC, outright positions, passive investors, passive trading program, pension plan, penultimate swaps, percentage interest, physical cal spread options, physical commodity, physical commodity deliverable, physical options, physically delivered contracts, Pirrong Testimony, PKVerleger LLC, pool participant, pool participant exemption, position limits, position visibility, pre-existing position exemption, price discovery, price risk, price spikes, price volatility, private equity investments, real-time basis, referenced contracts, regulatory oversight, reporting obligation, reporting requirements, risk management, risk transfer, risk-shifting market, rounding, seasonal variation, seasonality, self-executing disaggregation, short positions, significant price discovery contracts, speculative investment, speculative trading ventures, spot month, spot-month position limits, squeezes, statement of reporting trader, stock indices, submarket, supply and demand, surveillance, swap contract, swap dealer hedge exemption, swaps class all-months-combined, swaps class single-month, swaptions, The Economist, U.S. dollar, U.S. futures exchange, UK Treasury, university endowment, University of Calgary, University of Houston, Wall St. Journal, WTI,

MFA Letter to SEC on August 2007 New York Regional Office Examination Request Letter12.20.07


MFA submits comments to the SEC on the August 2007 New York Regional Office Examination Request Letter.

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Topics: adviser advisers, and VI(B)(1), arrangements, attorney-client privilege, August 2007 New York Regional Office Examination Request Letter, bankruptcy workout, broker-dealer, candidates, CCO Seminars or Roundtables, CCOutreach National Seminar, chief compliance officer seminars and roundtables, Chief Compliance Officers, Code of Ethics, compliance, complianceAlert, conflicts of interest, consistency, corporate insiders, data mining, Director of SEC's Office of Compliance and Inspections and Examinations, examination process, Federal Securities Laws, focus group, Form ADV Part II, hedge fund advisers, I(G), II(A)(2), II(A)(3), II(H)(1), III(M)(1), III(M)(3), III(N)(1), III(N)(2), IIIJ(1), Investor Protection, IX(F)(2)m X(I)(2), legal risk, Lori A. Richards, medium, Microsoft Excel spreadsheets, National society of compliance Professionals National Membership Meeting, New York Regional Office, Ninth Annual IA Compliance Best Pracitces SUmmit 2007, Office of Compliance Inspections and Examinations (OCIE), operations, periodic examinations, Pilot program, portfolio allocation, potential transactions, pre-examination letters operational resources, public, public company affiliation, public pension funds, registered investment advisers, registrants, regulations, relative, reqests II(D)(1), Request II(A)(1), Request II(B)(3), Request II(D)(3)(e), Request II(G)(1), Request II(J)(1), Request IV(A)(1)m block trades, Request V(A)(4), request V(G)(1), risk-based approach, risks, sales coverage, SEC, Securities and Exchange Commission, shareholder communications, standardized presentations, surveillance, technology, V(E)(2), V(E)(3), VIII(G), written complaint,
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