MFA Comment Letters

Topic: confidentiality

MFA and AIMA Submit Letter on Canadian Early Warning Reporting System07.12.13


MFA and AIMA submitted a letter to Canadian regulators in response to proposed amendments to Canada’s Early Warning System and […]

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Topics: Canada AIMA, MFA, Alternative Investment Management Association, Canadian Early Warning Reporting System, EWR, British Columbia Securities Commission, Alberta Securities Commission, Financial and Consumer Affairs Authority of Saskatchewan, Manitoba Securities Commission, Ontario Securities Commission, Autorite des Marches Financiers, New Brunswick Securities Commission, Superintendent of Securities Prince Edward Island, Nova Scotia Securities Commission, Securities Commission of Newfoundland and Labrador, Superintendent of Securities Yukon Territory, Superintendent of Securities Northwest Territories, Superintendent of Securities Nunavut, United Kingdom, transparency, securities law, Andrew Vollmer, Paul Wolfson, Alternative Monthly Reporting, shareholders, total return swaps, contracts for difference, derivatives, OTC derivatives, eligible institutional investor, institutional investors, board of directors, regulatory regime, capital markets, Ronald Gilson, Jeffrey Gordon, Brian Cheffins, Nickolay Gantchev, Chotibhak Jotikasthira, activist hedge fund, Hedge Funds Review, Canadian Coalition for Good Governance, National Bureau of Economic Research, corporate governance, remuneration, return on assets, performance, Kimber Report, investor reporting, reporting, non-objecting beneficial owners, beneficial owners, TSX, TSX Venture Exchange, System for Electronic Document Analysis and Retrieval, SEDAR, System for Insider Data on Insiders, SEDI, Yahoo!Finance, Stockhouse, Seeking Alpha, Reuters, StockCharts, Google Finance, Morningstar, Australia, Securities and Exchange Commission, SEC, disclosure and transparency rules, voting shares, equity securities, Financial Conduct Authority, FCA, London Stock Exchange, Issuer, Counterparty, relevant interests, Australian Securities and Investments Commission, ASIC, qualified investors, banks, broker-dealer, investment company, Bank of Canada, hedge funds, New York Stock Exchange, Australian Stock Exchange, liquidity, TMX Group Limited, Canada Pension Plan Investment Board, Ontario Teachers' Pension Plan, OMERS Administration Corporation, British Columbia Investment Management Corporation, The Caisse de depot et placement du Quebec, Alberta Investment Management Corporation, Ward Phillips & Vineberg LLP, confidentiality, cost-benefit analysis, disclosures, hedging, TELUS Corporation,

MFA Submits Letter and White Paper on Protection of Non-Public, Sensitive, and Proprietary Information by FSOC Members05.22.13


MFA submitted a cover letter and white paper to each member of the Financial Stability Oversight Council (FSOC) on the […]

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Topics: FSOC Financial Stability Oversight Council, market structure, SEC, CFTC, CTA, CPO, Securities and Exchange Commission, Commodity Futures Trading Commission, Dodd-Frank Act, market participants, financial stability, Managed Funds Association, Department of the Treasury, Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, FDIC, Federal Housing Finance Agency, National Credit Union Administration, Office of Financial Research, Federal Insurance Office, data collection, research, trade sectrets, liquidation, investment advisers, Richard H. Baker, U.S. House of Representatives Committee on Financial Services, data repositories, Trading Activities, harmonization, U.S. securities law, commodity pool operator, commodity trading advisor, self-regulatory organization, SRO, intermediary, broker-dealer, futures commission merchants, FCM, swap data repository, SDR, clearinghouses, systemic risk, Form PF, Form CPO-PQR, Form CTA-PR, registered investment adviser, adviser registration, substituted compliance, confidentiality, inspector general reports, Reverse Engineered, Trade Secrets, front running, SEC Office of Inspector General, Andrei Kirilenko, Adam Clark-Joseph, Jaksa Cvitanic, high frequency trading, National Institute of Standards and Technology, NIST, reporting, President Obama, information security program, Rulemaking, Council of Inspectors General on Financial Oversight, CIGFO, Security-Based Swap Data Repositories, SBSDR, Designated Clearing Organizations, DCO, Richard A. Shilts, legal entity identifiers,

MFA Submits Comments to the Monetary Authority of Singapore on Proposed Regulations on OTC Derivatives03.26.12


MFA submitted a comment letter to the Monetary Authority of Singapore (MAS) in response to its Consultation Paper on Proposed […]

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Topics: Monetary Authority of Singapore MAS, OTC derivatives, over-the-counter derivatives, Consultation Paper on Proposed Regulation of OTC Derivatives, G20, OTC derivatives market, systemic risk, efficient capital flows, mandary clearing, clearing, bilateral market, risk management, derivatives transactions, trading mandate, liquid and standardized transactions, client access to clearing, clearing arrangements, margin methodologies, straight-through processing, central clearing, Commodity Futures Trading Commission, CFTC, Gary Gensler, Securities and Exchange Commission, Mary Schapiro, market participants, central counterparty, CCP, average notional value, clearing threshold, buy-side clearing, U.S. Federal Reserve Bank of New York, Dodd-Frank Wall Street Reform and Consumer Protection Act, Dodd-Frank Act, backloading, Financial Stability Board, FSB, international harmonization of regulations, swaps, European Union, EU, European Commission, ESMA, legal entity identifiers, confidentiality, transaction data, counterparty identification, customized and proprietary investment strategies, intellectual property, International Organization of Securities Commissions, IOSCO, foreign regulator, financial entities, non-financial entities, Singapore, Form PF, margin requirements, netting, trading costs, aggregate counterparty credit risk, settlement risk, commercial banks, dealers, money changers, registered insurers, non-centrally cleared derivatives transactions, margin determinations, liquidation horizons, fragmentation of liquidity, clearing house, counterparty risk, recognized clearing houses, clearing facilities, real-time processing, barriers to entry, non-dealer client representation, risk committees, G20 commitments, regulatory regime, duplicative regulation, U.S. Senate Committee on Agriculture Nutrition and Forestry, trade repositories, Securities and Futures Commission, Honk Kong Monetary Authority,

Comment Letter to ESMA on its Technical Advice to the European Commission for Implementing AIFMD09.23.11


MFA submitted comments to ESMA on its consultation on Third Country Provisions in the AIFMD. In our response, among other […]

Comment Letter to ESMA on its Draft Technical Advice to the European Commission for Implementing AIFMD09.13.11


MFA submitted comments to ESMA on its consultation on possible implementing measures of the Alternative Investment Fund Managers Directive (AIFMD). […]

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Topics: AIFMD the directive, Level 2, third party managers, European Commission, consultation paper, AIF, UCITS Directive, MiFID, professional investors, retail investors, marketing, counterparties, prime brokers, net asset value, Article 61, AUM, AUM Calculations, mark-to-market, EU investors, sub-investment managers, Dodd-Frank, U.S. Securities and Exchange Commission, SEC, Investment Advisers Act of 1940, Advisers Act, registration, private funds, G-20, international coordination, Article 3(2), Article 9(3), professional indemnity insurance requirements, Gross Method, exposure, leverage, foreign exchange hedging position, interest rate hedging position, Box 93, Box 2, Box 1, NAV, Advanced Method, Box 13, diligence requirement, OTC transaction, securities lending agreement, repurchase agreement, Box 19, Box 29, risk management, risk limits, operational risk, portfolio management, market risk, portfolio risk, liquidity risk, gates, side pockets, redemption policy, depositaries, depositary, bespoke system, Box 78, collateral directive, Box 79, liability standards, Financial Services Authority, FSA, re-hypothecation provisions, Box 81, Box 86, due diligence, sub-custodian, Box 88, segregation, Box 89, omnibus accounts, liability regime, Box 95, Box 99, Value at Risk, VaR, Commitment Method, European Central Bank, ECB, Committee on European Securities Regulators, CESR Guidelines, credit default swap, CDS, remuneration, EU Passport, transparency, Box 106, passport regime, safe-keeping function, confidentiality, proprietary information, systemic risk, semi-annual reporting, collateral, counterparty exposures, Form PF, reporting period, generally accepted accounting principles (GAAP), Level 2 inputs, Level 3 inputs, valuation agents, underwriters, unobservable,

Comment Letter on Proposed Rule and Interpretation on Registration and Regulation of Security Based Swap Execution Facilities04.04.11


MFA submitted a comment letter to the SEC on its proposed rule and proposed interpretation on Registration and Regulation of […]