MFA Comment Letters

Topic: Disclosure

MFA Submits Letter in Response to SEC Investor Advisory Committee Recommendations on Implementation of the JOBS Act03.22.13


MFA submitted a comment letter to the Securities and Exchange Commission (SEC) in response to its proposed implementation of Section […]

MFA Submits Comments on AIFMD Remuneration09.27.12


MFA submitted comments to the European Securities and Markets Authority (ESMA) on its consultation on guidelines on sound remuneration policies […]

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Topics: ESMA European Securities and Markets Authority, remuneration, consultation paper, remuneration policies, AIFMD, European Union, EU, Policy Makers, proportionality principle, AIFM, excessive risk-taking, Identified Staff, limited liability partnership, LLP, management committees, junior partner, RemCo, deferral of remuneration and pension, European Commission, Council of the European Union, European Parliament, hedge fund managers, financial institutions, deposit-taking entity, government insurance, private placement, institutional investor, sophisticated investors, bank, Insurance, alignment of interests, owner-managed AIFM, shareholders, public shareholders, third country, Regulators, carried interest, fees, service providers, commissions, delegate, performance fee, Senior Management, investors, other risk taker, risk profile, Balance Sheet, own account dealer, operational risk, United Kingdom, affiliated group, governing body, Limited Liability Company, LLC, risk management, compliance, audit, compliance staff, counsel, chief compliance officer, control functions, parent company, credit institutions, capital requirements, MiFID, MiFID firms, distributions, minimum capital requirements, management bodies, non-executive directors, hedge funds, assets under management, AUM, Member State, Member State competent authorities, control function, pension, variable remuneration, risk alignment, material risk, UCITS, performance measures, deferred remuneration, non-deferred remuneration, Claw-Back, fee structure, redemption rights, tax, Tax Implications, bonuses, underperformance, alternative instruments, retention policy, financial stability, non-EU AIFM, marketing, EU Passport, private placement regime, Disclosure, Annual Report, Confidential Information, stakeholders,

Petition to SEC for Rulemaking on Rule 502 of Regulation D, Ban General Solicitation01.06.12


MFA submitted a comment letter to the SEC requesting that the Commission amend Rule 502(c) of Regulation D to eliminate […]

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Topics: Petition for Rulemaking Securities and Exchange Commission, SEC, Offers or Sales Securities, Private Funds Managers, Economic Growth, Competitiveness, Job Creation, Independent Regulatory Agencies, Investor Protections, Offerings or Sales, private funds, Administrative Costs, sophisticated investors, House of Representatives, United States Congress, Ban on General Solicitation and Advertising, Senate, Public Offering, investment company, Interpretive Framework, Broadcast Over Television, Radio, Fund Managers, Issuer, Selling Agent, Pre-Existing Substantive Relationship, Continuous Offerings, Limited Partnerships, Broker, accredited investors, Pre-Existing Relationship Doctrine, Qualified Potential Investors, Industry Conferences, Inquiries, Legal Costs, Business Practices, transparency, hedge funds, Policy Makers, Regulators, Proprietary Investment Data, Systemic Risk Assessment, Over-the-Counter Derivatives Markets, Disclosure, Third-Party, oversight, Private Offering, prime brokers, Auditors, General Solicitation, General Advertising, Fraud, Unsophisticated Investors, Ban on General Solicitation, Protecting Investors: A Half Century of Investment Company Regulation, Division of Investment Management, Investor Criteria, qualified purchasers, Division of Corporation Finance, Anti-Fraud Provisions, Wealth Tests, Federal Securities Laws, Chairman Schapiro, Congressman Darrell Issa, House Committee on Oversight and Government Reform, Investor Protection, capital formation, Inadvertent Violation, Waiting Period, Consulting Firm, Subscription Agreement,

Comment Letter in Response to the FDICs Interim Final Rule Implementing Certain Provisions of the Orderly Liquidation Authority (OLA),03.28.11


MFA filed a comment letter in response to the FDICs interim final rule implementing certain provisions of the orderly liquidation […]

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Topics: Federal Deposit Insurance Corporation FDIC, Liquidation Authority provisions, orderly liquid authority, OLA, creditor losses, shareholder losses, liquidation process, systemically significant firm, non-statutory considerations, Bankruptcy Code, Federal Rules of Bankruptcy Procedure, financial market meltdown, covered financial institution, insolvency laws, insolvency proceeding, investor, systemic risk, transparency, estate, creditor participation, creditor involvement, market expertise, Disclosure, claim disallowance, judicial review, distress, volatility, moral hazard, market discipline, receivership, short-term creditors, debt instrument, allocation of capital, short-term financing, longer-term financing, bond holders, short-term lenders, providers of lines of credit, preferred creditors, equality of distribution, critical vendors, doctrine of necessity, Union Bank v. Wolas, chapter 7 liquidation, favored creditors, unsecured creditors, Board of Directors of FDIC, ratable payments, liquidation value, valuation of collateral, underlying collateral, unsecured claim, fair market value, US government securities, valuation rules, true market valuation, unsecured deficiency claim, quotes, market data, third-party market participants, valuation date, publicly traded securities, secured creditor, receivership estate, market fluctuations, swaps, repurchase agreements, securities contracts, bridge financial company, default, contingent claims, unduly delay, liquidation framework,

Comment Letter to the CFTC on Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties02.22.11


MFA submitted a comment letter to the CFTC on its proposal on Business Conduct Standards for Swap Dealers and Major […]

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 to the Canadian Securities Administrators, Responding to Proposed Amendments to National Instrument 31-103, Registration of non-Canadian Investment Fund Managers01.13.11


On January 13, MFA filed a comment letter with the Canadian Securities Administrators in response to the CSAs proposed amendments […]