MFA Comment Letters

Related Legislation: National Securities Markets Improvement Act of 1996

Comment Letter Responding to SEC’s Proposal to Implement Amendments to the Advisers Act Contained in Title IV of the Dodd-Frank Act01.24.11


MFA submitted a comment letter todayto the SEC on its proposal to implement amendments to the Advisers Act contained in […]

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Topics: Securities and Exchange Commission De Minimis Amount, Investment Management, Richard H. Baker, Hearing on Industry Perspectives on the Obama Administration's Financial Regulatory Reform Proposals, Committee on Financial Services, U.S. House of Representatives, venture capital funds, private fund managers, Effective Date of Title IV, registration requirements, Mid-Sized Managers, Securities Commissioner, Exemption, hedge fund industry, Unregistered Managers, SEC-Registered Managers, Substantive Provision, effective date, net assets, Commission on Form ADV, Incentive-Based Compensation Arrangements, Hedge Fund Manager Registration Rul, performance fee, Income Thresholds, Grandfathering Provisions, equity owner, private adviser exemption, transitional relief, qualified purchaser, qualified client standard, Investment Adviser Registration Depository, IARD, SEC, Registration Process, SEC's Contract, IARD System, Duplicative Filing, NSMIA, Form ADV-T, regulatory assets under management, Proprietary Accounts of the Manager, Threshold of $25 Million, assets under management, Portfolios, investment adviser, Form ADV Part 1A, Instruction 5.b., threshold, registration, state securities commission, Mid-Sized Manager, SEC-registered investment advisers, Family Accounts, Proprietary Accounts, pooled investment vehicle, gross assets, hedge funds, leverage, collateral, counterparties, FSA, systemic risk, Basel Committee on Banking Supervision, Leverage Ratios, European Central Bank, Bank of America-Merrill Lynch, Columbia University, The Turner Review, Definition, proprietary information, valuation methodology, generally accepted accounting principles, GAAP, Debt-to-Equity, Instruction 5.b(4), Fair Value Methodology, International Accounting Standards, Difficult-to-Value Assets, Valuation Information, Private Fund Information, Compliance Risks, public disclosure, beneficial owners, Investor Protection Benefits, Fair Valu Hierarchy, Schedule D, Section 7.B.1, Proposed Items 14, 15, 17, 13 and 29, 11 and 12, $1 Billion, Incentive-Based, Excessive Compensation, banks, Credit Unions, broker dealers, assets, Proposed Items 5.A, 5.D and 5.F, Form ADV, Part 1A, Proposed Instruction 1.b., hedge fund managers, Depository Institutions, Taxpayer Money, National Securities Exchanges, Wealth and Income Requirements, Tier 1 Financial Holding Company, Compensation Structure, Unit-Linked Life Insurance,

Comment Letter to SEC Responding to Concept Release on Equity Market Structure05.07.10


MFA submitted a letter to the SEC in response to its request for comments on its Equity Market Structure Concept […]

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Topics: Securities and Exchange Commission SEC, Equity Market Structure, order handling rules, regulation ATS, decimalization, Regulation NMS, institutional investors, retail investors, liquidity, bid-ask spreads, transaction costs, technology, non-public trading, risk management, broker dealers, capital formation, long-term investors, short-term traders, registered investment advisers, private investment pools, pensions, endowments, foundations, insurance companies, direct market access, sponsored access, low latency technology, high frequency trading, HFT, automated trading, investor confidence, trading volume, order cancellations, market maker, specialist quotes, algorithm, quantitative strategies, global financial crisis, frontrunning, order anticipation, public information, momentum ignition, dark pools, Office of Economic Analysis, post-trade execution, National Market System, electronic communication networks, ECN, alternative trading systems, Intermarket Trading System Plan, ITS, Nasdaq, electronically accessibel quotes, New York Stock Exchange, NYSE, U.S. Department of Justice, National Association of Securities Dealers Inc., proprietary trading, electronic trading desks, inventory risks, inter-market arbitrage, price discovery, spreads, fees, execution speed, market depth, efficiency, transparency, Japan, Germany, United Kingdom, France, hedging, Market Crash of 1987, asset classes, fixed income, buyers, sellers, market fragmentation, investment time horizon, capital allocation, mutual fund, trading desk, competitive barriers, U.S Treasury bonds, Treasury ETF, large cap stocks, small cap stocks, securities lending, quote flickering, phantom liquidity, cancellation rate, limit orders, order protection rule, market consolidation, Designated Market Maker, volatility, short selling, market color, trends, sector change, co-location, price swings, pinging, upstairs market, post-trade transparency, connectivity vendors,

MFA Letter to Senate Republican Capital Markets Task Force Regarding United States Capital Markets Competitiveness in the Global Financial Services Marketplace02.29.08


MFA submits a comment letter to the Senate Republican Capital Markets Task Force in response to the Task Force’s request […]

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Topics: Senate Republican Capital Markets Task Force United States Congress, capital markets, U.S. Capital Markets, global financial system, regulatory regime, tax, capital formation, capital efficiencies, financial regulatory system, principles-based regulation, Securities and Exchange Commission, SEC, regulation, non-U.S. investors, capital, hedge funds, venture capital funds, oil and gas partnerships, Strategy and Financial Innovation, Investor Protection, Financial Services Roundtable, Blue Print for U.S. Financial Competitiveness, Commodity Futures Trading Commission, CFTC, safe harbor, exchanges, market crisis, market participants, duplicative regulation, public commodity pools, National Futures Association, NFA, Financial Industry Regulatory Authority, FINRA, commodity futures markets, energy commodities, Federal Energy Regulatory Commission, FERC, natural gas futures market, Federal Trade Commission, financial services industry, President's Working Group on Financial Markets, PWG, Department of the Treasury, Secretary of the Treasury, Federal Reserve Board, assets under management, investment advisers, retail investors, prudential regulators, Henry Paulson, Office of Compliance Inspections and Examinations, OCIE, Economic Club of New York, no-action letters, General Solicitation, General Advertising, transparency, Cross-Border, U.S. immigration policies, skilled non-U.S. professional workers, H-1B visa, student visa, harmonization, generally accepted accounting principles, GAAP, International Financial Reporting Standards, IFRS, mutual recognition, Canada, Enron Corporation, Cendant, Financial Services Forum, United Kingdom, European Union, EU, chilling effect, equity markets,

MFA Files Joint Comment Letter to California Department of Corporations on Proposed Rule Requiring Hedge Fund Managers to Register with the State11.21.07


MFA and the Coalition of Private Investment Companies submit a joint comment letter to the California Department of Corporations on […]

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Topics: Department of Corporations California Corporate Securities Law, Coalition of Private Investment Companies, CPIC, Commisioner of the California Department of Corporations, investment advisers, California, global alternative investment industry, hedge funds, managed future funds, proposal, Congress, jobs, office rents, support services, tax revenues, Investor Protection, de minimis standard, state registration, venture capital, investment adviser, national markets, Exemption, public, registered investment companies, private offerings, initial statement of reasons, jurisdiction, implications of the growth of hedge funds, 2003 staff report, industry trends, oversight, Fraud, fund advisers, Pension Funds, privately-offered pooled investment vehicles, due diligence, accredited investors, qualified purchasers, Board of Governors of the Federal Reserve System (FED), professional asset managers, fiduciary standards, New York, London, San Francisco, Exempt Advisers, financial products, risk, start-up companies, liquidation restrictions, locked up, Redemptions, capital calls, liscensing exemption, pooled investment vehicles, accredited investor standard, Private Offering, Form D, Data, electronic filing, requirement, Investor's Committee of the Advisory Group, financial market, Industry Standards, Agreement Among PWG and U.S. Agency Principals on Principles and Guidelines Regarding Private Pools of Capital, registrant, training personal, The Bureau of National Affairs, Sound Practices for Hedge Fund Managers, spillover effect, brokerage firms, James Chanos, chief investment officer, CalPERS, California Public Employees' Retirement System, Department of the Treasury, Commodity Futures Trading Commission, CFTC, President's Working Group on Financial Markets, PWG, Securities and Exchange Commission, SEC, assets under management, AUM, fund of funds,

MFA Comments to SEC Regarding Proposals to Revise Limited Offering Exemptions in Regulation D10.19.07


MFA submits a comment letter to the SEC regarding their proposals to revise the limited offering exemptions in Regulation D.

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Topics: Limited Coffering Exemptions global alternative investment industry, hedge funds, managed futures funds, policymaker, flexibility, issuers, Accerdited Investor, accredited natural person, offers, securities, limited announcement, offering, pooled investment vehicles, transactions, Public Offerings, General Solicitation, General Advertising, investor, accredited investor, higher dollar-amount thresholds, qualification, capital, Private Pooled Investment Vehicle Release, financial sophistication standards, federal regulations, natural persons, privated pools of captial, inflation, financial eligibility standard, joint income thresholds, Office of Economic Analysis, capital formation, compliance, implications of the growth of hedge funds, Offerings, private placement offerings, qualifies purchasers, Qualified Purchaser Definition, Qualified Client Definition, marital assets, Joint Investments, qualified client, qualified purchaser, Subscription Agreement, pooled investment fund, subscription agent, sophisticated investors, United States, Future Inflation Adjustment, dollar-amount threshols, private placement, knowledgeable employees, Trust Grantors, Trustees, beneficiaries, Sophisticated Investor Standards, risk, transaction costs, economic efficiency, Investor Protection, Investor relations professionals, research analysts, attorneys, traders, brokers, traders of a fund affiliate, senior financial, operational, accounting officers, risk/return, deferred compensation, net worth, investments tests, Issuer, fund principals, pooled investment funds, retention tool, start up company, sotck, equity owners, primary beneficiary, Grandfathered, inflation adjustments, dollar-amount thresholds, grandfather provision, due diligence, committed capital, Interation Safe Harbor, transparency, Manner of Offering, sale limitations, Disqualification Provisions, predecessor, affiliated issuer, director, executive officer, general partner, managing member, 20% beneficial owner, promoter, cease and desist, Fraud, Form D, blue sky filing, bad actor disqualification provisions, recdivism, Division of Enforcement, U.S. Congress, Securities and Exchange Commission, SEC, threshold,
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