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The Managed Funds Association ("MFA") and the Alternative Investment Management Association ("AIMA") submitted a letter to John Ramsay, Acting Director of the SEC's Division of Trading and Markets, to express buy-side concerns with the SEC's requirements for approving individual broker-dealer/futures commission merchant margin methodologies for the CDS customer portfolio margin program. In the letter, the MFA and AIMA request that the SEC make permanent its six-month uniform customer margin level. The letter asserts that the current uncertainty as to the eventual future minimum margin level

See below for date, rulemaking discussed, CFTC staff present, visitors, and organizations represented. WHEN: 9/11/2012 Rulemaking(s): Capital MarginGeneral CFTC Staff: John LawtonDoug LeslieStephen SherrodRiva AdrianceAmanda OlearJacqueline MesaJohn Riley Visitor(s): Jiri Krol, Director of Government and Regulatory Affairs (AIMA)Roy Katzovicz, Chief Legal Officer and Investment Team Member (Pershing Square Capital Management, LP)Jennifer Wood, Director, Head of Asset Management Regulation (AIMA)Hunter Moorhead (Crossroads Strategies) Organization(s): Alternative Investment Management

The SEC granted a request for relief from Section 11(d)(1) of the Securities Exchange Act of 1934 with respect to extensions of credit on ETF shares by Charles Schwab & Co., Inc. The SEC confirmed that Schwab could extend margin credit on the ETF shares in spite of the fact it had certain (very limited) business relationships with persons involved in the distribution of the shares. The relationship between Schwab and the ETF providers existed essentially to allow Schwab to hold conferences with respect to ETFs and would not have resulted in any direct cash compensation to Schwab. In effect