Comment Letters

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Comment Letter to the House of Lords Responding to Call for Evidence on Ensuring Safe and Sound Derivatives Markets02.01.10


House of Lords, European Union Sub-Committee A, call for evidence, European Commission, EU, EC, over-the-counter derivatives, OTC derivatives, hedge funds, […]

MFA Comments to the “Over-the-Counter Derivatives Markets Act of 2009”11.09.09


MFA submitted a letter to the Department of the Treasury regarding the Obama administration’s legislative proposal titled the “Over-the-Counter Derivatives […]

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Topics: Department of the Treasury Obama Administration, regulatory framework, over-the-counter derivatives, OTC derivatives, institutional investors, commodity, securities market, OTC derivatives market, derivatives transactions, central clearinghouse, segregation, initial margin, variation margin, trade and position reporting, swap dealers, securities dealers, Major Swap Participant, AIG, end-users, substantial net position, substantial unsecured net position, AAA credit rating, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, CFTC, security-based swaps, dealers, credit risk, insurance companies, energy companies, airline, utilities, private funds, local governmental entities, non-dealer entities, capital restrictions, swap market participant, Long Term Capital Management, Enron Corporation, thrift and insurance holding company, American International Group, unsecured current credit exposure, central clearing, derivatives clearing organizations, proprietary assets, legacy standardized swaps, non-clearable trade, Gary Gensler, Lehman Brothers, LBIE, collateral segregation, bankruptcy-remote, Bankruptcy Code, risk management, Pension Funds, endowments, hedge funds, custodian, ISDA product definitions, registered derivatives clearing organization, non-cleared swap transactions, exchange trading, hybrid market, exchange-traded products, market manipulation, position limits, physically-delivered commodities, cash-settled contracts, pre-merger notification regime, capital formation,

MFA Comments on Consultation on Increasing Short Position Transparency10.09.09


MFA submitted a letter to the Hong Kong Securities and Futures Commission (SFC) today in response to its Consultation Paper […]

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Topics: Securities and Futures Commission SFC, short positions, Hong Kong, manipulative conduct, short selling, efficiency, liquidity, public disclosure of short positions, price discovery, risk management, financial stocks, net long position, financial services sector, non-public disclosure, confidentiality, market participants, anonymised disclosure, short selling bans, global equity markets, bid-ask spreads, short sellers, short selling disclosure regime, transparency, cash markets, close out indicators, on-market transactions, derivatives, exchange trading, off-exchange transaction, hedging strategies, stocks, delta adjusted, designated securities, listed corporations, non-designated securities, OTC transaction, dual-listed securities, CESR, pan-European short selling disclosure regime, primary market, Hong Kong market, net short positions, transitory short position, reporting threshold, FSA, Financial Services Authority, Securities and Exchange Commission, SEC, turnover ratio, price volatility, capital raising, settlement, SEHK, market volatility, investment managers, private reporting, chilling effect, market efficiency, price formation, short squeeze, herding, volatility, institutional investors, retail investors, transaction costs, alternative investment classes, pensions, endowments, foundations, market liquidity, capital formation, convertible arbitrage, convertible bonds, copycat behavior, proprietary research, market making, Journal of Finance,

MFA Comments to SEC on Pay to Play Proposal10.06.09


MFA submitted a letter to the SEC today in response to its proposal to, among other things, restrict political contributions […]

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Topics: Securities and Exchange Commission SEC, pay to play practices, government assets, political contributions, investment adviser, investment management services, government entities, third party placement agents, municipal securities, Municipal Securities Rulemaking Board, MSRB, investment management industry, municipal underwritings, municipal securities underwriters, municipal securities professional, chief compliance officer, American Bar Association, Committee on Federal Regulation of the American Bar Association, state and local entities, legal authorities, compliance burden, agency, authority, instrumentality of the State, plan, program, pool of assets, political action committee, inauguration or transition committee, local or state political party, Foundation, charitable institution, government official, Regulators, covered associates, general partner, executive officer, Broker, Dealer, municipal securities business, municipal securities representative, municipal securities principals, sales principals, principal business unit, look-back provision, look-back period, securities firms, academic institutions, chilling effect, soliciting, personal political activities, beneficial owners, family members of covered associates, portfolio manager, written compliance policies and procedures, pre-approval procedures, disproportionately severe punishment, private fund, limited partnership, redemption rights, public pension plans, interest, contractual rights and obligations, management fees, liquidity, fund assets, redemption requests, investment services, fiduciary duty, assets, compensation arrangements, institutional investor, incentive fee structure, backward-looking provisions, operational challenges, compliance procedures, pooled investment vehicle, de minimi exception, returned contribution, Inadvertent Violation, inadvertent contribution, covered investment pool, registered investment companies, publicly offered securities, fund of funds, direct investment, platform arrangement, direct investors, third party placement agent, pension, third party solicitors, placement agent, hedge fund managers, hedge funds, offshore managers, marketing activities, broker-dealer, requests for proposals, due diligence, investment advisory services, investment techniques, investment objectives, risk management, anti-competitive effects, California Public Employees' Retirement System, CalPERS, CalSTRS, Los Angeles County Employees' Retirement System, Los Angeles City Employees' Retirement System, New Mexico Educational Retirement Board, Teacher Retirement System of Texas, Pennsylvania Public School Employees' Retirement System, Pennsylvania State Employment Retirement System, Connecticut, Massachusetts, Oklahoma, Washington, New York State Common Retirement Fund, New York City Employees' Retirement System, New Mexico Investment Council, New York, Illinois, pay to play scandals, Disclosure, transparency, state and federal laws, regulations, registration, cash solicitation, Wall St. Journal, code of ethics rule, compliance costs, Form ADV, registered investment adviser, unregistered adviser, pre-approval policies, affiliated broker-dealer,

MFA Comments to IRS on Application of FBAR to Private Investment Funds and Related Issues10.05.09


MFA submitted a letter to the IRS in response to IRS Notice 2009-62, which requests comments and recommendations concerning the […]

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Topics: Internal Revenue Service IRS, private investment funds, Reports of Foreign Bank and Financial Accounts, FBAR, hedge funds, private equity funds, Department of the Treasury, Financial Crimes Enforcement Network, FinCEN, filing obligation, foreign financial account, banks, publicly-held companies, non-public companies, chief financial officer, U.S.-based manager, Internal Revenue Code, FIRPTA, effectively connected income, financial institutions, foreign financial agencies, private sector, signatory authority, covered foreign financial account, commingled fund, Corporation, partnership, mutual funds, non-U.S. hedge fund, non-U.S. private equity fund, open-ended mutual funds, redemption terms, redemption policy, liquidity, financial accounts, New York State Bar Association, bank account, securities account, Lock-up, Tax Section of the New York State Bar Association, Neal S. Wolin, Michael Mundaca, Douglas H. Shulman, James H. Freis, third party transfers, broker-dealer, Passive Foreign Investment Companies, PFICs, PFIC shareholder filing requirements, Form 8621, Form 926, foreign corporations, Form 5471, Form 8865, U.S. tax return, Form 1065, non-U.S. hedge funds, money laundering, other authority, financial interest, master fund, hedge fund manager, Deferred Fees, hedge fund management companies, foreign prime brokerage, officer, partner, Investment Fund Managers, portfolio manager, investment officer, investment fund management company, Other Account Authority, Workbook on the Report of Foreign Bank and Financial Accounts, shareholders, investors, non-U.S. investors, primary owner, United States Person, domestic partnership, domestic corporation, domestic estate or trust, persons in and doing business in the United States, domestic taxpayers, safe harbor, U.S.-based managers,