MFA Comment Letters

Related Legislation: Advisers Act

Comment Letter to the SEC on Establishment of a Registration Regime for Municipal Advisors as Required by the Dodd-Frank Act.02.22.11


MFA submitted a comment letter to the SEC in response to its proposal to establish a registration regime for municipal […]

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Topics: Securities and Exchange Commission SEC, municipal advisors, duplicative registration, investment advisers, commodity trading advisors, CTAs, pooled investment vehicles, municipal financial products, municipal securities, guaranteed investment contracts, investment strategies, municipal escrow investments, pools of assets, pooled investment vehicle, municipal advisor, primary investors, private fund managers, solicitation, common control, third-party solicitor, SEC regulation, CFTC regulation, regulated persons, registered broker-dealer, pay to play rule, SEC-registered entities, registered investment advisers, registered CTAs, municipal advisory activities, municipal derivatives, commodity for future delivery, option, securities futures product, Security-Based Swap, bank deposits, investment advisory services, ancillary services, registered advisor, regular oversight, state-registered investment advisors, exempt reporting advisers, state entity, self-regulatory entity, state securities commission, mid-sized adviser, participating affiliate agreements, no-action letters, affiliate letters, SEC resources, multi-jurisdictional advisory firms, venture capital funds, private fund advisors, foreign private advisers, SEC No-Action Letter, Uniao de Banco de Brasileiros, Kleinwort Benson Investment Management Limited, Murray Johnstone Holdings Limited, ABN AMRO Bank N.V., Royal Bank of Canada, SEC oversight, transition period for registration, private adviser exemption, Form MA, dually-registered investment advisers, Form ADV,

Comment Letter to the Department of Labor in Response to the Departments Proposed Rule to Amend the Definition of Fiduciary Under ERISA02.03.11


MFA submitted a comment letter to the Department of Labor in response to the Departments proposed rule to amend the […]

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Topics: Employee Benefits Security Administration Department of Labor, DOL, ERISA, alternative investment vehicles, hedge funds, diversification, risk management, equity markets, fixed income markets, Joseph Dear, California Public Employees' Retirement System, Senate Banking Subcommittee on Securities, Insurance and Investment, pension fund, rate of return, fee structure, performance fee, total returns, hedge fund managers, risk-adjusted returns, high water marks, government safety new, pooled investment funds, Congress, Securities and Exchange Commission, SEC, Commodity Futures and Exchange Commission, CFTC, non-plan asset funds, plan asset vehicles, general partner, DOL regulations, equity securities, plan assets, market concern, Investor Protection, private investment fund, principal underwriter, fiduciary, appraisals, pricing services, custodians, appraisers, managing member, Internal Revenue Code, pooled investment vehicles, fiduciary liability insurance. prime brokerage, daily mark, swap counterparty, fund administration agreements, asset-based fee compensation, prohibited transaction provisions, net asset value, hard-to-value, private equity holdings, real estate holdings, side-pocket investments, appraisal of property, investment advisers, valuation firm, hedge fund manager, private pension, good faith estimate, may be considered standard, significantly influence standard, ERISA fiduciaries, mutual understanding, valuation of assets, "may be considered" advice, risk appetites, tailored advice, pooled investment fund, exemption applications, transaction reversal, excise taxes, selling exception, due diligence, adverse, marketing services, impartial investment advice, purchaser, seller, bilateral agreement, default, derivative markets, short sales, options, structured products, futures, settlement accommodations, overdraft coverage, inadvertent fiduciary status, pooled vehicle, market color, prime brokers, general partners,

Comment Letter Responding to SECs Proposed Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers With Less Than $150 Million in Assets Under Management, and Foreign Private Advisers01.24.11


MFA submitted a comment letter to the SEC in response to the SECs proposal Exemptions for Advisers to Venture Capital […]

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Topics: Securities and Exchange Commission SEC, Exemptions, venture capital funds, Private Fund Advisers, assets under management, foreign private advisers, Exemptions Release, Private Fund Registration, Statutory Exemption, commodity trading advisors, Single Investor Private Funds, investor, Commodity Futures Trading Commission, commodity trading advisor, CTA, Securities-Related Advice, CFTC, Peavey Commodity Futures Fund, SEC No-Action Letter, 1983 SEC No-Act. LEXIS 2576, Tonopah Mining Co. of Nevada, 26 S.E.C. 426, Subadvisers, Subsidiary Advisers, Regulatory Authority, Investment Adviser Industry, Specialized Expertise, Foreign Advisers and Subadvisers, no-action letters, Domestic, Non-U.S. Investment Advisory Firms, Control, Participating Affiliate, Mercury Asset Management Plc., affiliate letters, Registered and Non-Registered Entities, Factual Representations, Associated Persons, Full Regulatory Access, oversight, Non-Registered Adviser, Multi-Jurisdicational Advisory Firms, Non-U.S. Activities, systemic risk, Hedge Fund Adviser Registration Rules, Unio de Banco de Brasileiros S.A., Kleinwort Benson Investment Management Limited, AMRO Bank N.V., Royal Bank of Canada, ABA Subcommittee on Private Investment Entities, Compliance and Management Structures, Non-Control, affiliated entities, U.S. law, Non-U.S. Law, Affiliated Person, Form ADV, private fund, Master-Feeder Structure, Side-by-Side Structure, Specialized Feeder, Outstanding Voting Securities, pooled investment vehicle, limited partnership, Limited Liability Company, Independent Verification of Assets Requirement, general partner, Nominal Capital Account, Limited Partner, Instrument, total return swap, Record Owner, Equity Security, prudential regulators, Secretary of the Treasury, Security-Based Swap, Staff Responses to Questions About the Custody Rule, Question VI.11, Voting Rights, Redemption, Transparency Rights, regulatory assets under management, de minimis exemption, Regulatory Assets, separate account structure, Gross Assets Calculation, Fair Value, valuation methodology,

Comment Letter to the Canadian Securities Administrators, Responding to Proposed Amendments to National Instrument 31-103, Registration of non-Canadian Investment Fund Managers01.13.11


On January 13, MFA filed a comment letter with the Canadian Securities Administrators in response to the CSAs proposed amendments […]

Comment Letter Regarding SEC Study on the Whether the Establishment of a Self-Regulatory Organization Would Improve the Frequency of Examinations of Investment Advisers12.16.10


MFA submitted a letter today providing comments to the SEC on Section 914 of the Dodd-Frank Act, which requires the […]

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Topics: investment adviser examination self-regulatory organization, SRO, securities market, hedge fund managers, Securities and Exchange Commission, SEC, Commodities Futures Trading Commission, CFTC, private fund manager, capital formation, broker dealers, oversight, derivative, derivatives trading activities, investment activity, insider trading, short selling, Disclosure, purchase, sale, nregistered securities, broker-dealer, clearing agencies, over-the-counter derivatives, OTC derivatives, swap dealers, swaps, major swap participants, msp, initial margin, variation margin, transparency, Transaction Reporting, systemic risk, assets under management, leverage, trading positions, counterparties, liquidation, Investor Protection, Compliance Policies, chief compliance officer, Obama Administration's Financial Regulatory Reform Proposals, Committee on Financial Services, U.S. House of Representatives, Department of Labor, Department of the Treasury, National Association of Securities Dealers, NASD, over-the-counter securities markets, Office of Compliance Inspections and Examinations, OCIE, forensic accounting, compliance, registration, check-the-box, fiduciary duty, securities transactions, investment advisory firm, financial planners, traditional asset management firm, wealth managers, small advisers, mutual fund, pension, FINRA, Financial Industry Regulatory Authority, clearing, custody, securities lending, reporting, Financial Stability Oversight Council, FSOC, Investment Adviser Association and National Regulatory Services, Dodd-Frank Act,
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