MFA Comment Letters

Topic: collective investment vehicles

MFA and AIMA Submit Joint Letter to CFTC on Further Proposed Cross-Border Guidance02.06.13


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (CFTC) on its “Further Proposed Guidance […]

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Topics: Commodity Futures Trading Commission CFTC, Cross-Border, swaps, duplicative regulation, Alternative Investment Management Association, AIMA, Dodd-Frank Act, prime brokers, hedge fund managers, U.S. person, interpretive guidance, market participants, Corporation, partnership, Limited Liability Company, LLC, Trust, joint-stock company, direct or indirect ownership, commodity pool, pooled accounts, collective investment vehicles, commodity pool operator, CPO, pension, estate, income tax, principal place of business test, investment manager, limited liability partnership, LLP, investment fund, ownership test, derivatives, OTC derivatives, over-the-counter derivatives, OTC derivatives market, international harmonization of regulations, regulatory framework, swap dealer, Major Swap Participant, msp, Securities and Exchange Commission, SEC, European Securities and Markets Authority, ESMA, European Parliament, Council of the European Union, central counterparty, CCP, trade repositories, mandatory clearing requirements, clearing, central clearing, systemic risk, Gary Gensler, Mary Schapiro, OTC derivatives reform, CPPSS-IOSCO, IOSCO, International Organization of Securities Commissions, European Union, EU, Hong Kong Monetary Authority, Hong Kong, Monetary Authority of Singapore, Singapore, MAS, foreign regulators, Dealer, buy-side market participants, registration, adviser registration, Office of the Comptroller of the Currency, OCC, majority ownership, Look Through, fund of funds, listed entity, Form CPO-PQR, de minimis, commodities, phase-in period, execution, G20, G20 commitments, transparency,

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its “Proposed Interpretive Guidance […]

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Topics: CFTC Commodity Futures Trading Commission, interpretive guidance, swaps, Alternative Investment Management Association, AIMA, financial crisis, over-the-counter derivatives, OTC derivatives, OTC derivatives market, hedge fund industry, fund of funds, hedge fund managers, prime brokers, hedge fund administrator, market participants, non-U.S. market participants, regulatory requirements, commodity pool, pooled accounts, collective investment vehicles, non-U.S. investment fund, Securities and Exchange Commission, SEC, international harmonization of regulations, regulatory framework, duplicative regulation, transaction cost, compliance costs, U.S. person, non-U.S. persons, derivatives, derivatives markets, Corporation, partnership, limited liability companies, joint-stock company, fund, pension plans, estate, Trust, income tax, Jill Sommers, Scott O'Malia, cost-benefit analysis, market impact, third country, European Securities and Markets Authority, ESMA, direct or indirect ownership, Look Through, shareholders, listed entity, foreign banks, banks, dealers, commodity pool operator, CPO, Form CPO-PQR, financial stability, financial system, chief compliance officer, risk management, swap data recordkeeping, swap data reporting, commodity swaps, clearing, swaps processing, margining, segregation, uncleared swaps, execution, portfolio reconciliation, real-time public reporting, trade confirmations, Business Conduct Standards, qualified eligible person, accredited investors, general partnerships, registration, CPO registration requirements, counterparties, swap dealer, major swap participants, MSPs, swap data repository, sell-side firms, buy-side firms, entity-level requirement, reporting party, comment letter, transaction-level requirements, majority ownership, G20, G20 commitments, substituted compliance, transparency, Policy Makers, European Parliament, Council of the European Union, Hong Kong, Hong Kong Monetary Authority, Securities and Futures Commission, Monetary Authority of Singapore, Singapore, International Organization of Securities Commissions, IOSCO, Department of the Treasury, natural person, foreign entity, Dealer, fiduciary, International Monetary Fund, International Bank for Reconstruction and Development, Inter-American Development Bank, Asian Development Bank, African Development Bank, United Nations,

MFA Submits Letter to Department fo the Treasury Regarding Review by the Treasury Department of the Regulatory Structure Associated with Financial Institutions11.21.07


MFA submits letter to the U.S. Department of the Treasury in response to its request for recommendations on how to […]

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Topics: Department of the Treasury Regulatory Structure, optimal regulatory structure, marketplace, hedge funds, managed futures funds, Policy Makers, global alternative investment industry, trading business activties, United States, state securities regulators, regulatory oversight, regulatory framework, conflicting regulatory edicts, private sector self-regulation, Sound Practices for Hedge Fund Managers, peer-to-peer guidance for hedge fund managers, valuation, Portfolios, risk management, adequate disclosure, hedge fund investors, international organizations, International Organization of Securities Commissions (IOSCO), Market Particpants, public interest, market and financial integrity, United Kingdom's Financial Services Authority (FSA), Japan's Financial Services Agency, BaFin, Australia, Netherlands, twin peaks model, prudential safety, soundness regulation, conduct-of-business, U.S. capital market competitiveness, Investor Protection, market price transparency, principles-based approach, rules-based approach, flexibility, futures exchange, derivatives clearing organizations, safe harbor, compliance, exchange, statutory core principles, uniform set of basic principles of regulation, public interest goals, customer protections, retail foreign exchange (FX), transactions, Fraud, Congress, state regulators, local law enforcement, Europe, Financial Services Action Plan, Asian Countries, regions, international regulatory standards, costs, foreign markets, competitiveness concerns, G-8 finance ministers and deputies, international portfolio valuation principles, securities, futures, intermediaries, common stock, options contracts, ownership interest, capital raising process, stock index, natural gas, gold, wheat, stock price, stock world, net long, higher prices, short, fair prices, financial products, bonds, security futures, futures contracts, underlying asset, crude oil, currency options template, trading platforms, liquid trading markets, margin area, risk-based performance bond system, margin levels, options trading, natural gas futures price manipulation, substantial inefficiency, intemediary brokerage firms, duplicative systems, unwarranted costs, portfolio margining, collateral management stystems, financial integrity systems, net capital, cross-recognition efficiencies, commodity pool operator, private pools of capital, NFA, mutual, business models, retail customers, Disclosure, public managed futures fund offerings, FINRA, futures brokerage commission payments, federal government, wholesale, commercial, hedging, derivatives, commodity pool operators, collective investment vehicles, pool offerings, tired system of regulation, private transactions, counterparites, funds, exchanges, regulation of intermediaries, Henry Paulson, financial institutions, fund of funds, Securities and Exchange Commission, SEC, CFTC, Commodity Futures Trading Commission, Financial Industry Regulatory Authority, National Futures Association, President's Working Group on Financial Markets, PWG, Financial Services Roundtable, Federal Energy Regulatory Commission, FERC,
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