MFA Comment Letters

Topic: swap

MFA Submits Comments to SEC Supporting ICE Clear Credit’s Portfolio Margining Petition06.13.12


MFA submitted a comment letter to the SEC in support of ICE Clear Credit LLC’s portfolio margining petition.  In the […]

MFA Submits Comments to ESMA on Short Selling and Sovereign CDS03.09.12


MFA submitted comments in response to ESMAs public consultation on possible delegated acts concerning the Regulation on short selling and […]

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Topics: aggregation of positions AIFMD, Alternative Investment Fund Managers Directive, anti-avoidance provision, anticipated correlation, asset managers, Austria, bank name CDS, Belgium, BNP Paribas, broad-based indices, buffer periods, Buttersworth Journal of International Banking and Financial Law, CDS transaction, central clearing, CESR, civil law, clearing house, consolidated accounts, contract of insurance, convertible bond positions, convertible bonds, convertible debt, convertible debt securities, corporate bonds, correlation test, credit default swap, credit protection, credit quality, debt instruments, default risk, delegate, delta adjusted method, derivative instrument, disaggregation, emergent systemic risk, ESMA, ETF, EU Member State, European Securities and Markets Authority, Eurostoxx, eurozone, Financial Agency of Spain, financial institutions, financial instrument, forward rate agreement, France, FSA, fund management activities, future, Greece, group, hedged portfolios, holding a share, ICO, illiquid shares, indices, indirect exposures, Instituto de Credito Oficial, insurable interest, interest rate swap, interest rates, intra-Member State correlation, Ireland, IRS, IRS curve, issued share capital, Italian CDS, Italian CONSOB, Italian lira, Italy, legitimate market operations, Leonard Ng, Level 2 process, liquid market price, listed securities, long positions, margin level, market participants, Markit iTraxx SovX Western Europe Index, maturity bucket, Member State regulator, Ministry of Economy and Finance, money market instruments, narrow-based indices/baskets, natural or legal person, net short positions, netting, notional basis, option, OTC instruments, pan-European short selling disclosure regime, Portugal, proprietary models, publicly available information, quantitative threshold for high correlation, RBS, redenomination, reference asset, Regulation on short selling and certain aspects of credit default swaps, Secretariat of State for the Economy, sector-specific, securities law, sensitivity adjusted method, severe market turmoil, short sale, short selling, short selling bans, Societe Generale, sovereign bonds, sovereign CDS, sovereign CDS transactions, sovereign debt, sovereign issuer, Spain, static or dynamic hedging strategy, subordinated debt, supra-national European body, swap, tail risk, tail risk hedging, threshold of liquidity, trust preferred securities, UCITS, UK Financial Services Authority, uncovered credit default swap, uncovered position, uncovered short sales and credit default swaps, underlying shares, yield curve,

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

MFA Comments on CFTC Regulatory Intitiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

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Topics: "too big to fail AIG, bankruptcy law, Bondholder, business risk, capital markets, CCP, central clearing, central counterparties, CFTC, cleared swaps, clearing, collateral, Columbia University, commercial paper, Commodity Futures Trading Commission, commodity pool operator, commodity trading advisor, contract market, Counterparty, credit exposure, creditor, CTA, customer asset, customer protection, depositor, Designated Contract Market, endowments, equity market, FCM, FDIC, Federal Deposit Insurance Corporation, Federal Financial Institutions Examination Council, Federal Reserve, financial crisis, financial regulatory system, financial risk, Financial Stability Oversight Council, FSOC, futures, futures commission merchant, futures market, hedge funds, individual account, initial margin, institutional investors, international coordination, investment adviser, Investment Company Institute, investment portfolio, investor confidence, Investor Protection, leverage, liquidity, Major Swap Participant, managed funds, market discipline, market integrity, market maker, market stability, msp, non-bank MSP, non-swap dealer, Office of Financial Research, offsetting position, omnibus account, operational risk, OTC derivatives market, over-the-counter derivatives market, owned funds, Peavey Commodity Futures Fund no-action letter, pension plans, physical market, position limits, private investment funds, proprietary asset, proprietary strategies, regulatory capital requirements, reporting, residual value, risk capital, risk committee, risk management, risk model, roll-over, SEC, Securities and Exchange Commission, security-based swaps, SEF, segregation, substantial position, swap, swap dealer, Swap Execution Facility, systemic risk, TARP, third party custodian, Tier 1 capital, transparency, Troubled Asset Relief Program, U.S. Banking Industry, uncleared swaps, variation margin,

MFA Comments on SEC Regulatory Initiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

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Topics: "too big to fail accredited investor, AIFs, AIG, alternative investment funds, Bad Actors, bankruptcy law, beneficial ownership, Bondholder, Broker, business risk, capital formation, capital markets, CCP, central clearing, central counterparties, CFTC, cleared swaps, clearing, client, collateral, Columbia University, commercial paper, Commodity Futures Trading Commission, commodity pool operator, commodity trading advisor, Comptroller General of the United States, Confidential Information, contract market, Counterparty, covered financial institution, credit exposure, creditor, CTA, CUSIP number, customer asset, customer protection, depositor, Designated Contract Market, Disclosure, disqalifying felons, EC, endowments, EP, equity market, EU, European Commission, European Commissioner Michel Barnier, European Council of Finance Ministers, European Parliament, European Union, executive compensation, family office, FCM, FDIC, Federal Deposit Insurance Corporation, Federal Financial Institutions Examination Council, Federal Reserve, fiduciary, fiduciary standard, financial crisis, financial entities, financial regulatory system, financial risk, Financial Stability Oversight Council, Form SH, FSOC, futures, futures commission merchant, futures market, global banks, global market, hedge funds, herding, Incentive-Based Compensation Arrangements, individual account, initial margin, institutional investors, international coordination, investment adviser, investment adviser examination, Investment Company Institute, investment portfolio, Investor Advisory Committee, investor confidence, Investor Protection, knowledgeable employees, leverage, liquidity, Major Security-Based Swap Participant, Major Swap Participant, managed funds, many-to-many platform, margin requirement, market discipline, market integrity, market maker, market makers, market stability, msp, MSSP, mutual fund, non-bank financial companies, non-bank MSP, non-swap dealer, OCIE, Office of Compliance Inspections and Examinations, Office of Financial Research, offsetting position, omnibus account, operational risk, OTC derivatives market, over-the-counter derivatives market, owned funds, Peavey Commodity Futures Fund no-action letter, pension plans, performance reports, physical market, pooled investment vehicle, pooled vehicle, position limits, price discovery, Price Manipulation, private funds, private investment funds, proprietary asset, proprietary information, proprietary strategies, qualified client, registration, Regulation D, regulatory capital requirements, reporting, residual value, retail clients, retail funds, risk capital, risk committee, risk management, risk model, risk profile, roll-over, SEC, SEC-registered advisers, Secretary Geithner, Securities and Exchange Commission, security-based swaps, SEF, segregation, self-regulatory organization, short selling, short swing profit reporting, SRO, substantial position, swap, swap dealer, Swap Execution Facility, systemic risk, TARP, third party custodian, Tier 1 capital, transitional relief, transparency, Troubled Asset Relief Program, U.K. Chancellor of the Exchequer Alistair Darling, U.S. Banking Industry, uncleared swaps, variation margin, Venture Capital Fund, volatility,

MFA Letter to IOSCO Technical Committee Short Selling Task Force on Regulatory Approaches to Short Selling12.23.08


MFA sent a letter to the IOSCO Technical Committee Short Selling Task Force providing comments to regulatory approaches to short […]

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Topics: "delta" hedge aggregate basis, algorithmic trading, alternative investment vehicles, artificial price movements, automated systems, bid-ask spreads, bilateral swaps, broker-dealer, buy-side firms, capital markets, capital raising, chilling effect, clearing brokers, closed-out, CNS, Continuous Net Settlement, convertible bond, custodian banks, decimal pricing, derivatives, derivatives trading, distressed companies, easy to borrow shares, Electronic Blue Sheet system, endowments, Equity Security, European Corporate Governance Institute, exchanges, executing brokers, Financial Industry Regulatory Authority, FINRA, Florence Harmon, foundations, fraudulent short selling activity, hard to borrow shares, headline risk, hedge, hedging, high-volume trading, institutional investors, international harmonization of regulations, International Organization of Securities Commissions, John G. Gaine, liquidity, listed derivatives, locate, long positions, manipulative naked short selling, manual trading, market bubbles, market efficiency, market liquidity, market participants, Martin Wheatley, money managers, naked short selling, Nasdaq-listed securities, National Securities Clearing Corporation, NSCC, NYSE, NYSE-listed securities, OATS, Order Audit Trail System Rules, Order Tracking System, OTC derivatives, OTC equity securities, OTS, over-the-counter derivatives, pensions, Pre-borrow Emergency Order, pre-borrow requirement, price discovery, prime broker, proprietary investment strategies, public disclosure, reconciliation, registered market centers, Regulation Filing Applications, reverse engineer, risk, risk management, SEC, Securities and Exchange Commission, securities depositaries, sell-side firms, settlement, settlement date, short interest positions, short sale reporting, short selling, short squeeze, sub-penny quotes, swap, synthetic positions, systematic disturbances, Technical Committee of the International Organization of Securities Commissions, threshold security, trade reconciliation, transparency, unintentional failures to deliver, uptick rule, upward market manipulations, Yale International Center for Finance,
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