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Comment Letters
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| Posting date | | | | 12.8.2009 |  | MFA submitted a letter to the House Leadership, Ways and Means Committee Chairman Charlie Rangel (D-NY) and all Ways and Means Committee Members regarding the Tax Extenders Act of 2009 (H.R. 4213), which includes revenue offsets that would change the tax treatment of carried interest and provisions included in the “Foreign Account Tax Compliance Act of 2009” (H.R. 3933). In the letter, MFA cautioned that the tax extenders legislation could result in serious and negative consequences for U.S. capital markets, job growth and capital formation. In addition, the letter put forth MFA’s position with respect to the “Let Wall Street Pay for the Restoration of Main Street Act of 2009” (H.R. 4191), which would impose a transaction tax on all financial transactions. As stated in the letter, such a tax would significantly jeopardize our economy’s ability to recover. | | 12.1.2009 | | MFA submitted this letter on behalf of MFA members to House Financial Services Committee Chairman Barney Frank (D-MA) and all other Members of the Financial Services Committee. The letter 1) provides our views regarding the “Financial Stability Improvement Act of 2009”, the systemic risk and resolution authority legislation currently being considered by the Committee; 2) expresses our significant concern with the assessment mechanism being proposed to finance the new Systemic Resolution Fund; and 3) highlights our specific objection to the recent adoption of an amendment, offered by Representative Brad Sherman (D-CA), that would ‘carve-in’ hedge funds, making them subject to the assessment at an asset threshold lower than that which would apply to other financial institutions -- including those which may be systemically relevant. | | 11.25.2009 | | MFA submitted a letter to Subcommittee on Select Revenue Measures of the Committee on Ways and Means providing comments on the Foreign Account Tax Compliance Act of 2009 (H.R. 3933). In the letter, MFA makes recommendations regarding new tax compliance measures in the bill that would adversely impact private investment funds if they are not given adequate time for implementation. | | 11.9.2009 | | MFA submitted a letter to the Department of the Treasury regarding the Obama administration's legislative proposal titled the "Over-the-Counter Derivatives Markets Act of 2009" ("DMA"). A copy of the proposal can be found here. In our letter, MFA provided a number of comments, which we believe are consistent with the proposal's public policy goals and will further enhance the benefits of OTC derivatives regulation. | | 10.9.2009 | | MFA submitted a letter to the Hong Kong Securities and Futures Commission (SFC) today in response to its Consultation Paper on increasing short position transparency. In our letter, we recommend that: (i) any disclosure to the SFC should be non-public and fully protect the confidentiality of the information; (ii) reporting should be based on a de minimis reporting threshold for private reporting to the SFC of at least 0.5%; (iii) if there is evidence available that public disclosure is necessary and beneficial, the SFC should only make available to the public aggregated anonymised data on short selling using the information privately reported to it; and (iv) if the cost of producing aggregate anonymised data is too high, the SFC should consider publicly disclosing anonymised versions of individual private reports of short positions, but at a higher threshold (such as 2%). | | 10.6.2009 | | MFA submitted a letter to the SEC today in response to its proposal to, among other things, restrict political contributions by an investment adviser and its employees to officials of a government entity for which the adviser provides investment management services, and prohibit an adviser from paying a third party firm to solicit a government entity on its behalf. In our letter we recommend that the Commission: (i) narrowly tailor its proposals to prevent activities more likely to involve “pay to play” practices; (ii) amend the proposal to include appropriate terms for unintentional political contributions; and (iii) permit advisers to engage third party placement agents to solicit government entities, and adopt alternative rules that would more effectively address “pay to play” practices while allowing all advisers to compete for government clients. | | 10.5.2009 | | MFA submitted a letter to the IRS in response to IRS Notice 2009-62, which requests comments and recommendations concerning the compliance requirements for Reports of Foreign Bank and Financial Accounts (commonly referred to as “FBAR”). In our letter, we identify several issues relating to FBAR compliance and request guidance on how FBAR rules might apply to investments in hedge funds and similar private investment funds. |
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Industry Pulse
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Reuters
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Reuters
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American Banker
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The Financial Times
- Frank says Obama bank plan could be law within months
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MFA Calendar
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