MFA Comment Letters

Topic: Congress

Comment Letter on Proposed Rulemaking for Systemically Significant Institutions02.25.11


MFA submitted a letter to the Financial Stability Oversight Council in response to the Councils proposed rule regarding the criteria […]

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,

Letter to the European Commission in Response to its Consultation Paper, Review of the Markets in Financial Instruments Directive (MiFID)02.02.11


MFA submitted comments to the European Commission in response to its Consultation Paper, Review of the Markets in Financial Instruments […]

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Topics: European Commission Markets in Financial Instruments Directive, MiFID, regulatory framework, market stability, risk capital, proprietary strategies, surveillance tools, European Union, EU, financial regulatory system, hedge funds, OTC, commodity derivatives market, Investor Protection, title transfer collateral arrangements, non-retail clients, third country firms, "strict equivalence" regime, electronic trading platforms, liquid derivatives, exchange trading, exchange-traded products, European OTC derivatives markets, US markets, Asian Markets, ESMA, sufficiently liquid, European Commission on Standardisation and Organised Platform Trading of OTC Derivatives, Organised Trading Venues, cost-effective manner, reduced transaction costs, algorithmic trading, broker dealers, market impact, accurate price discovery, high frequency trading, HFT, market makers, low latency technology, strategy holding periods, horizon strategies, fleeting arbitrage opportunities, risk management, electronic market-making, technology-driven market makers, inventory risk, risk exposure, inter-market arbitrage, ultra low-latency technology, capital formation, automated execution technology, global connectivity infrastructure, financial institutions, market connectivity intermediaries, direct market access, flash crash, HFT trades, non-HFT trade, asset managers, insurance companies, banks, brokers, automated trading, arbitraging, minimum quantitative threshold, portfolio manager, alternative investment fund managers, AIFM directive, UCITS Directive, level playing field, non-EU asset managers, risk controls, pre-trade checks, SEC, Securities and Exchange Commission, circuit breakers, market-wide single stock circuit breakers, limit up system, limit down system, speed bumps, trading delays, specified maximum execution speeds, co-location facilities, latency, liquidity, investor confidence, technological innovation, short-term price swings, low latency technology chain, minimum tick sizes, liquid market, deep market, liquidity provision requirements, article 4(8) of MiFID, broker-dealer capital, margin requirements, concentrated risk solution, regulatory "tax, market efficiency, minimum duration of orders, limit orders, stale orders, affirmative and negative obligations, pre-trade transparency, post-trade transparency, investment strategies, safeguards, equity markets, waivers, dark pools, equity investors, pre-trade transparency waivers, order stubs, alternative trading systems, ATSs, indications of interest, IOIs, actionable IOIs, block sized trades, daily trading volume threshold, order-slicing methodologies, price discovery, post-trade reporting proposals, depositary receipts, exchange traded funds, certificates, UCITS, non-EU markets, non-EU investment firms, MiFID framework directive, non-equity instruments, comprehensive price date, comprehensive notional data, regulatory transparency thresholds, data consolidation, approved publication arrangements, APAs, European Consolidated Tape, Consolidated Tape, Congress, National Market System, composite quotation system, consolidated transaction reporting system, quotations, Consolidated Tape Association, opaque market centers, sharp shoot, order flow, US Securities Industry Automation Corporation, national best bid and offer, depth of market quotations, reporting protocols, third party information vendors, Securities Industry and Financial Markets Association, NetCoalition, Yahoo Inc, Google, Bloomberg L.P., depth-of-market fees, NetCoalition v. Securities and Exchange Commission, core date, consolidated core data, CQ plan, position-level data, harmonised position information, reasonable threshold, nexus, trader ID, transaction report, confidentiality obligation, client identifier, statutory obligation, OTC contract, trade repository, summary disclosure, ex-post disclosure, ex-ante disclosure, conflicts of interest, title transfer collateral arrangement, retail client, member states, cash balance, risk warnings, securities financing transaction, information requirements, due diligence obligations, third country regime, equivalence mechanism, strict equivalence, market disorder, systemic risk, unilateral bans, market turmoil, cost/benefit analysis, regulatory authorities, consultation papers, systemic risk grounds, CCP, capital flows, lending flows, credit flows, International Swaps and Derivatives Association, ISDA, G20, Financial Stability Board, European Market Infrastructure Regulation, EMIR, sovereign CDS, European Commission's report of Sovereign CDS, credit default swaps, CDS market, hedgers, hard position limits, physical commodity markets, market manipulation, position management, mechanical imposition, commodity derivatives, CESR, UK Treasury and Financial Services Authority, price movement, derivatives position, Disclosure, reporting obligations, transparency directive, security-based derivatives, European Commission Request for Additional Information in relation to the Review of MiFID, volatility, non-hedging, aggregate open interest/notional amount, reporting regimes, contract, market data,

Comment Letter Responding to the Financial Stability Oversight Council’s Advance Notice and Request for Comment on the Criteria for Designating a Nonbank Financial Company as Systemically Important.11.05.10


MFA submitted a comment letter to the Financial Stability Oversight Council in response to the Councils advance notice and request […]

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Topics: Systemically Important Institutions Financial Stability Oversight Council, FSOC, Nonbank Financial Company, Systemically Important Financial Companies, market participants, Systemic Risk Monitoring, Board of Governors, Federal Reserve System, Systemically Relevant Firms, Congress, "too big to fail, U.S. Financial Stability, hedge funds, Financial Market Participants, counterparty risk management, banks, broker-dealer, hedge fund industry, collateral, Borrowing, counterparties, capital markets, financial system, global mutual fund industry, U.S. Banking Industry, systemic risk, assets under management, leverage, Colombia University, Investment Company Institute, Federal Financial Institutions Examination Council, BofA Merrill Lynch, risk monitoring, due diligence, Collateral Posting, credit exposure, Structure of the Industry, Financial Assets, investment portfolio, sophisticated investors, ultra-high net worth individuals, retail investors, diversified portfolio, Liquidity Restrictions, Periods of Redemption, Redemptions, gates, Side Pocket Vehicles, Highly Illiquid Assets, alignment of interests, performance fees, high water marks, risk-adjusted returns, Legally Distinct Funds, Common Adviser, financial institutions, insurance companies, Long Term Capital Managment, LTCM, Position Size, Inadequate Counterparty Risk, leverage ratio, OTC Derivatives Trades, OTC, Counterparty Risk Management Policy Group, Fed Chairman Bernanke, Securities Exchange Commission, SEC, regulatory regime, over-the-counter derivatives, Standardized Transactions, swap dealers, major swap participants, CFTC, Cleared Transaction, Uncleared Transaction, margin requirements, prime brokerage, Short-Term Funding, overnight borrowing, asset mix, off-balance sheet exposures, bank holding companies, Equity Capital Stability, FDIC, FDIC deposit insurance, Debt Guarantees, Government-Issed Charter, Government-Funded Capital, Troubled Asset Relief Program, TARP, Federal Reserve's Discount Window,

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,

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 IOSCO’s Call for Views on Issues That Could Be Addressed by IOSCO on Funds of Hedge Funds08.03.07


MFA submits comments in response to IOSCO’s “Call for Views on Issues that Could Be Addressed by IOSCO on Funds […]

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Topics: IOSCO FOHF Report, Investor Protection Issues, U.S. Funds of Hedge Funds, investment companies, Exemption, Disclosure, recordkeeping requirements, Commodity Pools, global alternative investment industry, hedge funds, managed futures funds, policymakers, absolute return strategies, private sector initiatives, hedge fund industry, United States, public sector, Federal Reserve, state agencies, Congress, private sector, major dealers, derivative market practices, international advisory and government bodies, United Kingdom's Financial Services Authority, Securities Exchange Board of India, retail investors, Full Part 4 Funds, Full Part 4 CPOs, Company Act FOHFs, IOSCO Technical Committe Standing Committee on Investment Management, retail investors' increased investment in FOHF's, IOSCO Report, Retail investment, retail market, regulatory regime, offering disclosure regime, advertising rules, Investor Protection, disclosure requirements, senior securities, management agreements, transactions, broker dealers, Financial Industry Regulatroy Authority, NASD, New York Stock Exchange, Investor Suitability, Manner of Offering, accredited investors, securities, private offering exemption, safe harbor, Public Offering, offering, mass mailings, General Solicitation, advertisement, open-end investment companies, mutual, liquidity, shareholders, periodic tender offers, high net worth requirements, qualified clients, natural person, adviser, net worth, initial investment requirements, retail funds, disclosure documents, compliance, compliance examinations, Company Act Registration, investment company, board members, interested persons, counsel, annual self-assessment, executive session, assets, bank, custody, broker-dealer, bank custodians, chief compliance officer, compliance policies and procedures, Federal Securities Laws, codes of ethics, fraudulent or manipulative practices, personal securities transactions, principal transactions, underlying fraud, outstanding voting, Affiliated Person, non-voting interests, agency transactions, asset coverage, company obligations, shares, dividends, borrowings, derivative instruments, advisory contracts, diversification, real estate, shareholder approval, breaches of fiduciary duty, compensation, registration statements, Form N-SAR, principal executive, principal financial officers, material fact, record keeping requirements, for cause examinations, sweep examinations, adviser operations, Subscription Agreement, verbatim risk of loss disclosure statements, table of contents, business background, risk factors, volatility, leverage, counterparty creditworthiness, commodities, margin obligations, fees, expenses, break-even chart, conflicts of interest, soft dollar, directed brokerage arrangements, futures brokers, tansferability and redemption rights, tax, liability, investor's capital contribution, undistributed profits, financial reporting to investors, Annual Report, Plain English Requirements, NFA Notice I-07-25, state securities regulators, statement of additional information, Company Act Disclosure Requirements, closed-end investment companies, Form N-2, prospectus, fee table, sales loads, offering price, dividend reinvestment, cash purchase plan fees, transaction fees, net assets, common shares, management fees, interest payments, borrowed funds, acquired fund fees, total annual expenses, initial investment, a 5% annual return, rask factors, public trading market, portfolio managers, Plain English Principles, glossaries, technical terms, administrators, custodians, affiliated broker, tax consequences, net asset value, capital stock, voting, liquidation, material pending legal proceedings, committee structure, ownership of shares, family of investment companies, proxy voting, independent registered public accounting firm, performance fees, securities transactions, tax status, offering prive, underwriters, legends, high risk, annual financial statements, independent public accountant, periodic statements, U.S. generally acceped accounting principles, accrual method of accounting, an oath or affirmation, unaudited semi-annual reports, fiscal period, Portfolio Holdings, advisory contract, Form N-CSR, Senior officer code of ethics, audit committee financial expert, audit, audit-related, share repurchases, U.S. GAAP, total return, futures professionals, promotional material, prospective investors, cherry picking, IOSCO Technical Committee, Securities and Exchange Commission, SEC, CFTC, Commodity Futures Trading Commission, commodity pool operator, CPO, fund of funds, Department of the Treasury, MFA's Sound Practices for Hedge Fund Managers, National Futures Association, NFA, FINRA,

MFA Letter to NASD Regarding Proposed Rule on Member Private Offerings07.20.07


MFA submits comments to the NASD regarding NASD Proposed Rule 2721, Member Private Offerings, requesting that privately offered commodity pools […]