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The Application of Commodity Pool Rules to Insurance Linked Securities
The Application of Commodity Pool Rules to Insurance Linked Securities October 15, 2012 The Dodd-Frank Act’s expansion of the definition of “commodity pool” to include any form of enterprise operated for the purpose of trading in “swaps,” coupled with the Commodity Futures Trading Commission (“CFTC”) and the Securities and Exchange Commission (“SEC”) recently adopting an expansive definition of the term “swap” for purposes of the Dodd-Frank Act and the Commodity Exchange Act, creates uncertainty regarding whether issuers of insurance linked securities (“ILS”) are commodity pools that would require the registration of commodity pool operators (“CPO”) and commodity trading advisors (“CTA”) with the CFTC. Expansive Definition of Swap On July 10, 2012, pursuant to a joint release (“Joint Release”) the CFTC and the SEC adopted final rules, which became effective on October 12, 2012, broadly defining the term “swap” to include, in addition to those contracts commonly known as swaps (including interest rate swaps, floors and caps, currency swaps and credit default swaps), “any agreement, contract or transaction that provides for any purchase, sale, payment or delivery..... that is dependent on the occurrence of an event or contingency associated with a potential financial, economic, or commercial consequence.” This expansive definition will encompass a broad array of contracts including those customarily underlying cat bond and other ILS transactions, unless such contracts are specifically not considered swaps under the rules or are otherwise -
Arbitrage Pricing Theory∗
ARBITRAGE PRICING THEORY∗ Gur Huberman Zhenyu Wang† August 15, 2005 Abstract Focusing on asset returns governed by a factor structure, the APT is a one-period model, in which preclusion of arbitrage over static portfolios of these assets leads to a linear relation between the expected return and its covariance with the factors. The APT, however, does not preclude arbitrage over dynamic portfolios. Consequently, applying the model to evaluate managed portfolios contradicts the no-arbitrage spirit of the model. An empirical test of the APT entails a procedure to identify features of the underlying factor structure rather than merely a collection of mean-variance efficient factor portfolios that satisfies the linear relation. Keywords: arbitrage; asset pricing model; factor model. ∗S. N. Durlauf and L. E. Blume, The New Palgrave Dictionary of Economics, forthcoming, Palgrave Macmillan, reproduced with permission of Palgrave Macmillan. This article is taken from the authors’ original manuscript and has not been reviewed or edited. The definitive published version of this extract may be found in the complete The New Palgrave Dictionary of Economics in print and online, forthcoming. †Huberman is at Columbia University. Wang is at the Federal Reserve Bank of New York and the McCombs School of Business in the University of Texas at Austin. The views stated here are those of the authors and do not necessarily reflect the views of the Federal Reserve Bank of New York or the Federal Reserve System. Introduction The Arbitrage Pricing Theory (APT) was developed primarily by Ross (1976a, 1976b). It is a one-period model in which every investor believes that the stochastic properties of returns of capital assets are consistent with a factor structure. -
Arbitrage Pricing Theory: Theory and Applications to Financial Data Analysis Basic Investment Equation
Risk and Portfolio Management Spring 2010 Arbitrage Pricing Theory: Theory and Applications To Financial Data Analysis Basic investment equation = Et equity in a trading account at time t (liquidation value) = + Δ Rit return on stock i from time t to time t t (includes dividend income) = Qit dollars invested in stock i at time t r = interest rate N N = + Δ + − ⎛ ⎞ Δ ()+ Δ Et+Δt Et Et r t ∑Qit Rit ⎜∑Qit ⎟r t before rebalancing, at time t t i=1 ⎝ i=1 ⎠ N N N = + Δ + − ⎛ ⎞ Δ + ε ()+ Δ Et+Δt Et Et r t ∑Qit Rit ⎜∑Qit ⎟r t ∑| Qi(t+Δt) - Qit | after rebalancing, at time t t i=1 ⎝ i=1 ⎠ i=1 ε = transaction cost (as percentage of stock price) Leverage N N = + Δ + − ⎛ ⎞ Δ Et+Δt Et Et r t ∑Qit Rit ⎜∑Qit ⎟r t i=1 ⎝ i=1 ⎠ N ∑ Qit Ratio of (gross) investments i=1 Leverage = to equity Et ≥ Qit 0 ``Long - only position'' N ≥ = = Qit 0, ∑Qit Et Leverage 1, long only position i=1 Reg - T : Leverage ≤ 2 ()margin accounts for retail investors Day traders : Leverage ≤ 4 Professionals & institutions : Risk - based leverage Portfolio Theory Introduce dimensionless quantities and view returns as random variables Q N θ = i Leverage = θ Dimensionless ``portfolio i ∑ i weights’’ Ei i=1 ΔΠ E − E − E rΔt ΔE = t+Δt t t = − rΔt Π Et E ~ All investments financed = − Δ Ri Ri r t (at known IR) ΔΠ N ~ = θ Ri Π ∑ i i=1 ΔΠ N ~ ΔΠ N ~ ~ N ⎛ ⎞ ⎛ ⎞ 2 ⎛ ⎞ ⎛ ⎞ E = θ E Ri ; σ = θ θ Cov Ri , R j = θ θ σ σ ρ ⎜ Π ⎟ ∑ i ⎜ ⎟ ⎜ Π ⎟ ∑ i j ⎜ ⎟ ∑ i j i j ij ⎝ ⎠ i=1 ⎝ ⎠ ⎝ ⎠ ij=1 ⎝ ⎠ ij=1 Sharpe Ratio ⎛ ΔΠ ⎞ N ⎛ ~ ⎞ E θ E R ⎜ Π ⎟ ∑ i ⎜ i ⎟ s = s()θ ,...,θ = ⎝ ⎠ = i=1 ⎝ ⎠ 1 N ⎛ ΔΠ ⎞ N σ ⎜ ⎟ θ θ σ σ ρ Π ∑ i j i j ij ⎝ ⎠ i=1 Sharpe ratio is homogeneous of degree zero in the portfolio weights. -
Introduction and Overview of 40 Act Liquid Alternative Funds
Introduction and Overview of 40 Act Liquid Alternative Funds July 2013 Citi Prime Finance Introduction and Overview of 40 Act Liquid Alternative Funds I. Introduction 5 II. Overview of Alternative Open-End Mutual Funds 6 Single-Manager Mutual Funds 6 Multi-Alternative Mutual Funds 8 Managed Futures Mutual Funds 9 III. Overview of Alternative Closed-End Funds 11 Alternative Exchange-Traded Funds 11 Continuously Offered Interval or Tender Offer Funds 12 Business Development Companies 13 Unit Investment Trusts 14 IV. Requirements for 40 Act Liquid Alternative Funds 15 Registration and Regulatory Filings 15 Key Service Providers 16 V. Marketing and Distributing 40 Act Liquid Alternative Funds 17 Mutual Fund Share Classes 17 Distribution Channels 19 Marketing Strategy 20 Conclusion 22 Introduction and Overview of 40 Act Liquid Alternative Funds | 3 Section I: Introduction and Overview of 40 Act Liquid Alternative Funds This document is an introduction to ’40 Act funds for hedge fund managers exploring the possibilities available within the publically offered funds market in the United States. The document is not a comprehensive manual for the public funds market; instead, it is a primer for the purpose of introducing the different fund products and some of their high-level requirements. This document does not seek to provide any legal advice. We do not intend to provide any opinion in this document that could be considered legal advice by our team. We would advise all firms looking at these products to engage with a qualified law firm or outside general counsel to review the detailed implications of moving into the public markets and engaging with United States regulators of those markets. -
Minutes of the Meeting Held on August 6, 2020 Present: Francis Murphy
Minutes of the meeting held on August 6, 2020 Present: Francis Murphy – Chairman, James Monagle, Michael Gardner, Nadia Chamblin- Foster, John Shinkwin, David Kale, Ellen Philbin, Rafik Ghazarian and Chris Burns. The meeting was called to order at 11:05 AM. The meeting was digitally recorded. Agenda Item #1 – Segal Marco Advisors Ghazarian reviewed Segal Marco’s written analysis of investment performance for the period ending June 30, 2020. Markets bounced back strongly following the losses in the early part of the year, but still remain negative on a year-to-date basis. Ghazarian reviewed the system’s current asset allocation. The system funded the investment with the Pinebridge bank loans fund in July. The system is slightly short of the target allocation in real estate. The hedge fund allocation was cut and is now targeted to 5% of the portfolio. Overall, the total fund was valued at $1.322 billion, representing a gain of 9.94% during the quarter. The fund underperformed with the policy index return of 13.99%. Ghazarian stated that part of this underperformance was attributable to the underperformance of value stocks. Another issue was the drop in the price of Cambridge Bancorp stock, which dragged down the entire equity sleeve. Lazard has also continued to underperform. The hedge fund sleeve also saw poor performance, returning 1.25% in the last quarter, vs. the benchmark at 7.25%. Ghazarain stated that a number of his clients had asked about “recovery funds” which have advertised returns of 15-20%. He noted that some similar funds had very strong performance after the 2008 financial crisis. -
CFTC Proposes Rules Governing Automated Trading
CLIENT MEMORANDUM CFTC Proposes Rules Governing Automated Trading December 22, 2015 AUTHORS Rita M. Molesworth | Deborah A. Tuchman | James E. Lippert The Commodity Futures Trading Commission has proposed broad new regulations governing automated and algorithmic trading.1 The proposed regulations focus on automation of order origination, transmission and execution, and the risks that may arise from that activity. As proposed, Regulation AT would require, among other things, the implementation of pre-trade risk controls at multiple stages along the life-cycle of a trade. Regulation AT would apply to current CFTC registrants that engage in algorithmic trading and potentially also require some currently unregistered entities to register with the CFTC as floor traders if they have direct electronic access to a designated contract market (“DCM”). Regulation AT would also require the National Futures Association (“NFA”) to consider adopting additional membership rules relevant to algorithmic trading. Comments on the proposed rule are due by March 16, 2016. Key Definitions Regulation AT would add or amend certain definitions to CFTC regulations, most notably: “Algorithmic Trading” would generally be defined as trading in any commodity interest on or subject to the rules of a DCM, where (i) one or more computer algorithms or systems determine whether to initiate, modify or cancel an 1 Regulation Automated Trading, 80 Fed. Reg. 78824 (Dec. 17, 2015) (“Regulation AT”). 1 CFTC Proposes Rules Governing Automated Trading Continued order, or make certain other determinations with respect to an order, and (ii) such order, modification or order cancellation is electronically submitted for processing on or subject to the rules of a DCM. -
34-55547; File No
SECURITIES AND EXCHANGE COMMISSION (Release No. 34-55547; File No. SR-Amex-2006-110) March 28, 2007 Self-Regulatory Organizations; American Stock Exchange LLC; Order Granting Approval of Proposed Rule Change Relating to Options Based on Commodity Pool ETFs I. Introduction On November 24, 2006, the American Stock Exchange LLC (“Amex” or “Exchange”) filed with the Securities and Exchange Commission (“Commission”), pursuant to Section 19(b)(1) of the Securities Exchange Act of 1934 (“Act”)1 and Rule 19b-4 thereunder,2 a proposal to amend certain rules to permit the listing and trading of options on securities issued by trust issued receipts (“Commodity TIRs”), partnership units, and other entities (referred herein to as “Commodity Pool ETFs”) that hold or invest in commodity futures products. The proposed rule change was published for comment in the Federal Register on February 6, 2007.3 The Commission received no comments regarding the proposal. This order approves the proposed rule change. II. Description of the Proposal The purpose of the proposed rule change is to enable the listing and trading on the Exchange of options on interests in Commodity Pool ETFs that trade directly or indirectly commodity futures products. As a result, Commodity Pool ETFs are subject to the Commodity Exchange Act (“CEA”) due to their status as a commodity pool,4 and therefore, regulated by the 1 15 U.S.C. 78s(b)(1). 2 17 CFR 240.19b-4. 3 See Securities Exchange Act Release No. 55187 (January 29, 2007), 72 FR 5467. 4 A “commodity pool” is defined in CFTC Regulation 4.10(d)(1) as any investment trust, syndicate, or similar form of enterprise operated for the purpose of trading commodity interests. -
Regulation Automated Trading: Cftc Source Code Turnover Provision Is Unnecessary and Dangerous to U.S
REGULATION AUTOMATED TRADING: CFTC SOURCE CODE TURNOVER PROVISION IS UNNECESSARY AND DANGEROUS TO U.S. MARKETS Thomas Laser* Abstract Over the past several decades, the financial markets have experienced a technological revolution in how securities and other financial instruments are traded. Where these contracts and assets were once traded on the floors of various registered brick and mortar exchanges across the globe, they are now primarily traded via online platforms. While allowing greater efficiency and transparency in the markets, this shift has also spawned the practice of high-frequency algorithmic trading. This process uses highly sophisticated computers and complex algorithms to trade securities and derivative products faster than the human eye can blink. Although many argue that high-frequency algorithmic trading accounts for a great deal of liquidity in our markets and creates transparency with regard to prices, many feel that the nature of the practice creates the potential for extreme instability in the markets as well. Such instability has been exhibited periodically through occurrences known as “flash crashes.” In response to these events, the Commodity Futures Trading Commission has drafted legislation, known as Regulation Automated Trading, aimed at controlling the extent to which algorithmic trading can disrupt the marketplace. However, several of the provisions have come under a great deal of scrutiny. In particular, one provision provides that those engaging in high-frequency algorithmic trading make their source code (the algorithmic code which drives their business) available to regulatory agencies at any time. This Article analyzes the costs and benefits of high-frequency algorithmic trading, and how Regulation Automated Trading oversteps its bounds in trying to regulate the industry. -
CFTC Proposes Rulemaking Regarding Automated Trading
December 2, 2015 CFTC Proposes Rulemaking Regarding Automated Trading CFTC Proposes Regulation AT to Impose Registration, Pre-Trade Risk Control and System Safeguard Requirements for Automated Trading Firms and Related Obligations for Clearing Members and Exchanges INTRODUCTION On November 24, 2015, the Commodity Futures Trading Commission (the “CFTC” or “Commission”) voted unanimously to issue proposed rules to implement a framework of registration, compliance, recordkeeping and reporting rules for market participants engaging in algorithmic (or automated) trading activity. The proposal would also impose algorithmic trading compliance and oversight obligations on clearing member futures commission merchants (“clearing member FCMs”) and designated contract markets (“DCMs” or “exchanges”) and would impose a range of new requirements on DCMs. The proposed algorithmic trading rules (collectively, proposed “Regulation AT”), which would largely codify a range of existing industry best practices, follows the CFTC’s September 2013 Concept Release on Risk Controls and System Safeguards for Automated Trading Environments, in which the Commission originally solicited public comments on how best to address the transition to an automated and interconnected trading environment. Regulation AT includes proposed definitions for several previously undefined terms, notably including algorithmic trading, an AT Person (as used herein, “AT Person”), and direct electronic access (or “DEA”). The proposal does not define high-frequency trading, and instead is designed to apply to all algorithmic or automated trading, regardless of the speed of trading. Regulation AT would also require firms that are not otherwise registered with the CFTC in some other capacity, and that trade via DEA, to register with the CFTC as floor traders. New York Washington, D.C. -
Fifty Leading Women in Hedge Funds 2020
Fifty Leading Women in Hedge Funds 2020 I N A S S O C I A T I O N W I T H 50 LEADING WOMEN IN HEDGE FUNDS 2020 50 LEADING WOMEN IN HEDGE FUNDS 2020 Introduction HAMLIN LOVELL, CONTRIBUTING EDITOR, THE HEDGE FUND JOURNAL his is the eighth edition of our managers of all time – according to LCF Edmond 50 Leading Women in Hedge de Rothschild analysis – namely Bridgewater Funds report and is published Associates and Lone Pine. The two Lone Pine in association with EY for the women in this year’s report are two of the three seventh time. Whilst Covid-19 portfolio managers who succeeded Lone Pine’s has denied us the opportunity founder Steve Mandel. Three of the report’s to host accompanying events discretionary equity portfolio managers specialize in London and New York, at in the healthcare and biotechnology sector, which least this year, the professional achievements has attracted more attention this year for obvious Tof the women featured in this year’s report reasons. Four of the investment professionals shine through, nonetheless. We are so pleased work for systematic and quantitative hedge fund An analysis of the S&P to be publishing this report just a few days after managers, which is notable given the general Kamala Harris made history by becoming the dearth of women in STEM. Another noteworthy first female, first black and first Asian-American cluster is three women managing multi-billion Composite 1500 found US Vice-President-elect. s the leading global evidence is clear. Having more amounts in liquid credit strategies. -
The Impact of Index and Swap Funds on Commodity Futures Markets: Preliminary Results”, OECD Food, Agriculture and Fisheries Papers, No
Please cite this paper as: Irwin, S. and D. Sanders (2010-06-01), “The Impact of Index and Swap Funds on Commodity Futures Markets: Preliminary Results”, OECD Food, Agriculture and Fisheries Papers, No. 27, OECD Publishing, Paris. http://dx.doi.org/10.1787/5kmd40wl1t5f-en OECD Food, Agriculture and Fisheries Papers No. 27 The Impact of Index and Swap Funds on Commodity Futures Markets PRELIMINARY RESULTS Scott H. Irwin Dwight R. Sanders TAD/CA/APM/WP(2010)8/FINAL Executive Summary The report was prepared for the OECD by Professors Scott Irwin and Dwight Sanders. It represents a preliminary study which aims to clarify the role of index and swap funds in agricultural and energy commodity futures markets. The full report including the econometric analysis is available in the Annex to this report. While the increased participation of index fund investments in commodity markets represents a significant structural change, this has not generated increased price volatility, implied or realised, in agricultural futures markets. Based on new data and empirical analysis, the study finds that index funds did not cause a bubble in commodity futures prices. There is no statistically significant relationship indicating that changes in index and swap fund positions have increased market volatility. The evidence presented here is strongest for the agricultural futures markets because the data on index trader positions are measured with reasonable accuracy. The evidence is not as strong in the two energy markets studied here because of considerable uncertainty about the degree to which the available data actually reflect index trader positions in these markets. -
Dr Tom Howat Spent Seven Years at Trinity College, Cambridge, Studying Applied Mathematics, and Graduating with a Phd in Mathematical Biology in 2006
The RingTHE JOURNAL OF THE CAMBRIDGE COMPUTER LAB RING Issue XXXII — January 2013 — £20 The Cambridge Phenomenon 5 Ring news 2 64 4 Letter from the Editor Kick-starting Chip Design The Raspberry Pi Effect Who’s who 3 Valobox 64 6 Making it easier and cheaper to Hall of fame news 9 access paid content through the Web Skin Analytics 8 A mobile health app to give you peace of mind Tom Howat 11 Graduate Story www.camring.ucam.org 2 Ring news Letter from the Editor Events calendar As many of you probably know the In contrast with his fellow economics gradu- Computer Laboratory’s graduate association, ates, Julian Hall eschewed the traditional 2013 Cambridge Computer Lab Ring, is open not path to the City and instead took up an only to all graduates and present and former industrial placement at IBM. His time with February staff of the Computer Laboratory, but also a successful start-up in Auckland taught him Cambridge graduates from other disciplines “how malleable software technology can Wednesday 6th, 6.30pm working in computing careers. be” and he set his sights on staying in the London Ringlet Bar industry. Julian has recently co–founded a Venue to be confirmed While many in industry throughout the company in Cambridge (page 8). April land and far beyond bemoan the lack of computer science graduates, the relentless While Tom Howat’s move into technology Thursday 4th, 6.30pm growth of new technologies has served to is perhaps more traditional (he does come London Ringlet Bar attract a diverse cadre of the most capable from the STEM fields having spent seven Venue to be confirmed graduates from other disciplines.