MFA Comment Letters

Topic: de minimis

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,

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

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Topics: private funds commodity pool operators, commodity trading advisors, Form PF, systemic risk, Financial Stability Oversight Council, market participants, managed futures, absolute return strategies, SEC, CFTC, Dodd-Frank Act, Council and Office of Financial Research, OFR, global regulators, overcounting, undercounting, threshold for enhanced performance, assets under management, reporting period, confidentiality protections, inadvertent disclosure, non-bank financial companies, lending institutions, interconnectedness, liquidity risk, maturity mismatch, regulatory scrutiny, systemically significant, Federal Reserve System, the Fed, Form CPO, Form PQR, Form CTA-PR, targeted requests, tiered reporting system, threshold, trading and investment strategies, borrowing arrangements, collateral practices, operational capabilities, illiquid assets, investment advisers, bespoke contracts, private equity, privately issued convertible bonds, equity derivatives, distressed debt, unaffiliated third party sources, generally accepted accounting principles, GAAP, Level 2 inputs, Level 3 inputs, Financial Accounting Standards Board, audited financial statements, UK Financial Services Authority, FSA, Form 13F, public companies, Form 10-K, Form 10-Q, portfolio management, CUSIP number, semi-annual reporting, counterparty exposures, market noise, short-term market fluctuations, margin requirements, hedge fund defaults, large private fund manager, qualifying fund, hedge fund assets under management, Form ADV, proposed reporting thresholds, interpretive guidance, private fund managers, recordkeeping requirements, section 404, confidentiality of information, proprietary information, Investment Adviser Registration Depository, Schedule 13G, individual certification, valuation methodology, proprietary methodology, alternative methodology, de minimis, master-feeder, parallel funds, equity prices, interest rates, currency rates, Form PF question 36, form PF questions 28 and 35, funds of funds, direct investments, aggregate gross asset value, collateral, operational efficiency, ten-year option, five-year option, master agreement, regulatory assets under management, net assets under management, leverage, parallel managed accounts, net asset value, gross asset value, creditor, net borrowings, aggregate borrowings, beneficial owners, record owners, fixed advisory fees, investment expenses, performance fees, inception class, statistical arbitrage-equity, other quantitative strategies, strategy exposure, risk capital allocation, NAV, futures commission merchants, FCMs, direct clearing members, DCMs, prime brokers, clause (iii), loan commitments, offsetting exposure, tri-party collateral accounts, market value, asset-backed securities, debt securities, swap contracts, futures contracts, foreign currency contracts, notional value of derivatives, notional amount, long positions, short positions, LMV, SMV, maturity brackets, short-term interest rate, DV01, CR01, duration, non-rated issues, short term high quality corporate debt, foreign exchange derivatives, turnover rate, GMV, Bloomberg, risk methodology, repos, sensitivity analyses, liquidity management, balance sheet value, delta adjusted, variation margin, equity exposure, rehypothecated initial margin, CCPs, central clearing counterparties, Value at Risk, VaR, CDS, CDX, default rates, corporate bonds, short borrowing, synthetic borrowing, uncommitted lines of credit, side pocket arrangement,

MFA Response to CESR Consultation Paper on a Proposal for a Pan-European Short Selling Disclosure Regime10.01.09


MFA submitted a letter to the Committee of European Securities Regulators (CESR) today in response to its Consultation Paper on a […]

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Topics: Committee of European Securities Regulators CESR, CESR Proposal for a Pan-European Short Selling Disclosure Regime, alternative investment managers, hedge funds, fund of funds, hybrid funds, 130/30 funds, managed futures funds, industry service providers, alternative investment industry, absolute return strategies, short selling, manipulative conduct, Market Confidence, stability, public disclosure of short positions, short positions, market volatility, price discovery, risk management, risk management function, significant adverse effect, financial services sector, investors, Issuer, market participants, de minimis, aggregated anonymised data, timeframe for reporting, transparency directive, meaningful data, short selling bans, global equity markets, academics, liquidity, bid-ask spread, price declines, materially negative impacts, market efficiency, short selling disclosure regime, equity markets, enhanced transparency, investment managers, abusive short selling practices, abusive practices, financial institutions, herding, institutional investors, retail investors, transaction costs, capital markets, free flow of information, chilling effect, alternative investment classes, Pension Funds, endowments, foundations, alternative investment vehicles, hedging strategies, capital formation, hedge, convertible arbitrage, short equity position, convertible bonds, traditional bond issuance, convertible securities, short squeeze, Reverse Engineered, trading strategies, long equity positions, exposures, Unwind, financial stocks, pricing efficiency, short selling prohibitions, European markets, large-scale short selling, extreme market conditions, negative returns, UK Financial Services Authority, FSA, securities prices, naked short selling, Journal of Finance, Credit Suisse, market stability, disclosure thresholds, private reporting, flagging short sales, Financial Regulatory Authority, FINRA, flagging regime, disproportionate costs, real time information, over-the-counter transactions, exchanges, trading platform, settlement, physical short sales transactions, EEA stock, extraterritoriality, European Union, EU, EEA equities, two-tier disclosure model, price amplification, market testing, MiFID, competent authorities, Member State competent authorities, professional secrecy, confidentiality, freedom of information regimes, harmonization, net economic short positions, transitory short position, abusive behavior, share issues, capital raising, index trading, basket trade, reporting regimes, net economic short position, asset management company, aggregation, prudential regulators, T+1 reporting, derivatives, derivative positions, delta adjusted, cumulative compliance costs, global capital markets, EU Member State, market maker, market making,