MFA Comment Letter to ISDA on Independent Amount White Paper

MFA submitted a letter to the International Swaps and Dealers Association (ISDA) to provide comments to the penultimate draft of the Independent Amount White Paper. In our letter, MFA raises a number of concerns regarding, among others, the neutrality of the first part of the paper, which is supposed to provide a factual explanation of the risks association with over-collateralization of independent amounts under ISDA Credit Support Annexes. MFA also submitted its markup to the draft.