MFA Comment Letters

Topic: cost-benefit analysis

MFA Submits Comments in Response to SEC Proposed Amendments to Regulation D, Form D and Rule 15609.23.13


MFA submitted a letter to the Securities and Exchange Commission in response to proposed amendments to Regulation D, Form D […]

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Topics: Securities and Exchange Commission SEC, Regulation D, Form D, market practices, JOBS Act, General Solicitation, private placements, capital formation, Investor Protection, transparency, private fund, private capital markets, hedge funds, issuers, due diligence, John Thune, registered investment companies, RICs, private fund managers, examination process, Office of Compliance Inspections and Examinations, OCIE, hedge fund industry, assets under management, AUM, Form ADV, state securities regulators, Form PF, proprietary information, Rulemaking, adviser registration, Norm Champ, Division of Investment Management, PLI Hedge Fund Management Conference, Advance Form D, cost-benefit analysis, compliance costs, registered investment adviser, hedge fund managers, compliance, public markets, Fund Sponsors, United States Congress, capital markets, Form 13F, Schedule 13D, censure, cease and desist, Verification Methods, accredited investor, general solicitation materials, legends, disclosure requirements, anti-fraud rules, performance, sophisticated investors, high net worth requirements, institutional investor, private fund offerings, retail investors, private placement memorandum, Ban on General Solicitation and Advertising, accredited investors, efficiency, competition, pitch book, marketing materials, beneficial owners, equity, natural persons, eligible purchasers, general partner, Federal Securities Laws, deemed compliant, Pacific Mutual Life Insurance Company, Variable Life, Franklin Group of Funds, investment company, statement of policy, mutual fund, interpretive guidance, commodities, derivatives, liquidity, qualified purchasers, qualified clients, Global Investment Performance Standards, investor qualification standards, knowledgeable employees, harmonization, Elizabeth Murphy, Commodity Futures Trading Commission, CFTC, pool participants, Ray Garrett, Colorado Bar Association,

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 to CFTC on Proposed Rules on Enhancing Customer Protections02.15.13


MFA submitted a comment letter to the Commodity Futures Trading Commission (CFTC) on its proposed rulemaking on “Enhancing Protections Afforded […]

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 ESMA on Straight-Through-Processing08.05.12


On August 5, MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) to advocate for the […]

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Topics: ESMA European Securities and Markets Authority, OTC derivatives, CCP, trade repositories, straight-through processing, regulatory technical standards, EMIR, over-the-counter derivatives, derivatives, European Parliament, Council of the European Union, OTC derivatives transactions, central counterparty, systemic risk, counterparty credit risk, credit risk, market access, efficiency, operational market processes, clearing, execution, executing counterparty, market participants, clearing obligation, documentation, clearing member, interest rate swap, credit default swap, CDS, CME, Chicago mercantile exchange, alternative liquidity providers, liquidity, risk, electronic trading, bilateral derivatives transactions, bilateral master agreements, risk management, real-time processing, Commodity Futures Trading Commission, CFTC, Designated Contract Market, DCM, Swap Execution Facility, SEF, execution platform, Allocations, cost-benefit analysis, European Union, EU, ESMA Task Forces, transparency, OTC Derivatives Task Force, CCP Requirements Task Force, Trade Repositories Task Force, derivatives transactions, international harmonization of regulations, Financial Stability Board, FSB, European Commission, delegated acts, customer clearing documentation, directive, due diligence, operational risk, Court of Justice of the European Union, Continental Cans, EU Member State, Commission v. Council ERTA, financial stability, Christopher Seagon v. Deko Marty Belgium NV, clearing agreement, financial system, United States, Dodd-Frank Act, real-time acceptance, competition, settlement, liquidity fragmentation, central limit order books, International Swaps and Dealers Association, ISDA, bid-ask spread, limit check, trading venues, credit intermediation, derivatives markets, bilateral risk management, volatility, derivatives clearing organization, DCO, swap dealer, Major Swap Participant, dealer-to-dealer clearing, dealer-to-customer platforms, mandatory clearing, clearinghouse, bilateral credit agreement, bilateral market, competitive liquidity, block transactions, investment managers, breakage, Futures Industry Association, FIA, trading desk, anti-competitive effects, ICE energy swaps, ICE Clear Credit LLC, LCH Clearnet, clearing acceptance process, trilateral documentation, designation notice, Managed Funds Association, bundled trade, futures, futures market, credit limit order bookc, credit limit, interconnectedness, dealers, real economy, pension fund, endowments, institutional investors, Liquidity Providers, trilateral clearing agreements, energy derivatives, technical standards, voice execution, matched transactions, direct clearing members, credit limits, risk-based, latency, transaction capture facility, anti-competitive restrictions, aggregate limit, underlying clients,

MFA Submits Comment Letter to CFTC on Proposed Dodd-Frank Implementation Rules for Mandatory Swap Clearing, Trade Execution, and Margin Rules11.04.11


The OTC derivatives reforms (Title VII) resulting from the Dodd-Frank Act will cause sweeping transformation of the OTC derivatives markets […]

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Topics: Commodity Futures Trading Commission CFTC, swaps, swap transaction, swap transaction compliance, clearing, trade execution, margining, margining requirements, Dodd-Frank Act, mandatory clearing, Rulemaking, Gary Gensler, central clearing, market participants, buy-side participants, end-user exemptions, product definition rules, Securities and Exchange Commission, SEC, security-based swaps, swap dealer, Security-Based Swap Dealer, Major Swap Participant, Major Security-Based Swap Participant, collateral, full-scale clearing, uncleared swaps, liquidity, execution, Category 2 Entities, Category 1 Entities, active fund, buy-side market participants, private funds, swap execution facilities, SEF, Designated Contracts Markets, DCMs, real-time reporting, swap data, Regulators, derivatives clearing organization, futures commission merchants, FCM, non-dealer market participants, clearing mandate, G20, OTC derivatives, over-the-counter derivatives, exchanges, electronic platform, central counterparties, CCP, federal register, class of swaps, voluntary clearing, Category 3 Entities, Scott O'Malia, compliance schedules, compliance date, made available for trading, partial tear-ups, novations, third-party subaccount, non-MSP counterparties, interest rate swaps, broad-based index credit default swaps, commodity swaps, systemic risk, real-time clearing, cost-benefit analysis, price distortion, bilateral execution, execution venue, listing, security-based swap SEF, Category 4 Entities, trading documentation, phased implementation, transparency, prudential regulators, variation margin, netting, counterparties,

Supplementary Letter to the SEC in Response to its Proposed Antifraud Rule with Respect to Security-Based Swaps03.29.11


MFA submitted a letter to supplement our December 23, 2010 letter to the SEC in response to its proposed antifraud […]

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Topics: Securities and Exchange Commission SEC, Fraud, Manipulation, Deception, security-based swaps, anti-fraud rule, security based swaps market, cost-benefit analysis, honest markets, legitimate market activity, US OTC derivatives market, derivatives market, swaps market, legitimate market participation, purchase, sale, definitions, statutory authorization, security based swap anti-fraud rule, Securities Industry and Financial Markets Association, International Swaps and Derivatives Association Inc, The Loan Syndications and Trading Association, maturity date, context, bilateral contracts, novations, unwinds, assignments, execution, termination, assignment, exchange, transfer of rights/obligations, conveyance of rights/obligations, extinguishment of rights/obligations, total return swaps, credit default swaps, transferor, credit events, corporate actions, underlying shares, disruption events, termination events, collateral, systemic risk, interim payments, premium payments, spread payments, material non-public information, ISDA master agreement, clearing agreement, counterparty defaults, bankruptcy proceedings, Bankruptcy Code, automatic stay provisions, price discovery process, fair dealing, competition, capital formation, Financial Crisis Inquiry Commission, single name credit default swaps, non-index multi-name credit default swaps, equity linked forwards, equity-linked swaps, unallocated swaps, Bank of International Settlements, BIS, price discovery, primary participant, secondary participant, credit exposure, equity exposure, institutional leveraged loans, investment grade bonds, Financial Stability Board, primary debt issuance, investment grade loans, leveraged loans, LBO-related loans, corporate loans, high yield bonds, Loan market Review, Reuters, SEC v. Rotech, FCIC, CDS market, swap market, financial crisis, price efficiency, investor confidence, material dislocation,