MFA Comment Letters

Topic: transparency directive

Letter to the European Commission in Response to its Consultation Paper, Review of the Markets in Financial Instruments Directive (MiFID)02.02.11


MFA submitted comments to the European Commission in response to its Consultation Paper, Review of the Markets in Financial Instruments […]

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Topics: "strict equivalence" regime accurate price discovery, actionable IOIs, affirmative and negative obligations, aggregate open interest/notional amount, AIFM directive, algorithmic trading, alternative investment fund managers, alternative trading systems, APAs, approved publication arrangements, arbitraging, article 4(8) of MiFID, Asian Markets, asset managers, ATSs, automated execution technology, automated trading, banks, block sized trades, Bloomberg L.P., broker dealers, broker-dealer capital, brokers, capital flows, capital formation, cash balance, CCP, CDS market, certificates, CESR, circuit breakers, client identifier, co-location facilities, commodity derivatives, commodity derivatives market, composite quotation system, comprehensive notional data, comprehensive price date, concentrated risk solution, confidentiality obligation, conflicts of interest, Congress, consolidated core data, Consolidated Tape, Consolidated Tape Association, consolidated transaction reporting system, consultation papers, contract, core date, cost-effective manner, cost/benefit analysis, CQ plan, credit default swaps, credit flows, daily trading volume threshold, dark pools, data consolidation, deep market, depositary receipts, depth of market quotations, depth-of-market fees, derivatives position, direct market access, Disclosure, due diligence obligations, electronic market-making, electronic trading platforms, EMIR, equity investors, equity markets, equivalence mechanism, ESMA, EU, European Commission, European Commission on Standardisation and Organised Platform Trading of OTC Derivatives, European Commission Request for Additional Information in relation to the Review of MiFID, European Commission's report of Sovereign CDS, European Consolidated Tape, European Market Infrastructure Regulation, European OTC derivatives markets, European Union, ex-ante disclosure, ex-post disclosure, exchange traded funds, exchange trading, exchange-traded products, financial institutions, financial regulatory system, Financial Stability Board, flash crash, fleeting arbitrage opportunities, G20, global connectivity infrastructure, Google, hard position limits, harmonised position information, hedge funds, hedgers, HFT, HFT trades, high frequency trading, horizon strategies, indications of interest, information requirements, insurance companies, inter-market arbitrage, International Swaps and Derivatives Association, inventory risk, investment strategies, investor confidence, Investor Protection, IOIs, ISDA, latency, lending flows, level playing field, limit down system, limit orders, limit up system, liquid derivatives, liquid market, liquidity, liquidity provision requirements, low latency technology, low latency technology chain, margin requirements, market connectivity intermediaries, market data, market disorder, market efficiency, market impact, market makers, market manipulation, market stability, market turmoil, market-wide single stock circuit breakers, Markets in Financial Instruments Directive, mechanical imposition, member states, MiFID, MiFID framework directive, minimum duration of orders, minimum quantitative threshold, minimum tick sizes, national best bid and offer, National Market System, NetCoalition, NetCoalition v. Securities and Exchange Commission, nexus, non-equity instruments, non-EU asset managers, non-EU investment firms, non-EU markets, non-hedging, non-HFT trade, non-retail clients, opaque market centers, order flow, order stubs, order-slicing methodologies, Organised Trading Venues, OTC, OTC contract, physical commodity markets, portfolio manager, position management, position-level data, post-trade reporting proposals, post-trade transparency, pre-trade checks, pre-trade transparency, pre-trade transparency waivers, price discovery, price movement, proprietary strategies, quotations, reasonable threshold, reduced transaction costs, regulatory "tax, regulatory authorities, regulatory framework, regulatory transparency thresholds, reporting obligations, reporting protocols, reporting regimes, retail client, risk capital, risk controls, risk exposure, risk management, risk warnings, safeguards, SEC, Securities and Exchange Commission, securities financing transaction, Securities Industry and Financial Markets Association, security-based derivatives, sharp shoot, short-term price swings, sovereign CDS, specified maximum execution speeds, speed bumps, stale orders, statutory obligation, strategy holding periods, strict equivalence, sufficiently liquid, summary disclosure, surveillance tools, systemic risk, systemic risk grounds, technological innovation, technology-driven market makers, third country firms, third country regime, third party information vendors, title transfer collateral arrangement, title transfer collateral arrangements, trade repository, trader ID, trading delays, transaction report, transparency directive, UCITS, UCITS Directive, UK Treasury and Financial Services Authority, ultra low-latency technology, unilateral bans, US markets, US Securities Industry Automation Corporation, volatility, waivers, Yahoo Inc,

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