MFA Comment Letters

Topic: Fair Value

Comment Letter Responding to SECs Proposed Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers With Less Than $150 Million in Assets Under Management, and Foreign Private Advisers01.24.11


MFA submitted a comment letter to the SEC in response to the SECs proposal Exemptions for Advisers to Venture Capital […]

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Topics: Securities and Exchange Commission SEC, Exemptions, venture capital funds, Private Fund Advisers, assets under management, foreign private advisers, Exemptions Release, Private Fund Registration, Statutory Exemption, commodity trading advisors, Single Investor Private Funds, investor, Commodity Futures Trading Commission, commodity trading advisor, CTA, Securities-Related Advice, CFTC, Peavey Commodity Futures Fund, SEC No-Action Letter, 1983 SEC No-Act. LEXIS 2576, Tonopah Mining Co. of Nevada, 26 S.E.C. 426, Subadvisers, Subsidiary Advisers, Regulatory Authority, Investment Adviser Industry, Specialized Expertise, Foreign Advisers and Subadvisers, no-action letters, Domestic, Non-U.S. Investment Advisory Firms, Control, Participating Affiliate, Mercury Asset Management Plc., affiliate letters, Registered and Non-Registered Entities, Factual Representations, Associated Persons, Full Regulatory Access, oversight, Non-Registered Adviser, Multi-Jurisdicational Advisory Firms, Non-U.S. Activities, systemic risk, Hedge Fund Adviser Registration Rules, Unio de Banco de Brasileiros S.A., Kleinwort Benson Investment Management Limited, AMRO Bank N.V., Royal Bank of Canada, ABA Subcommittee on Private Investment Entities, Compliance and Management Structures, Non-Control, affiliated entities, U.S. law, Non-U.S. Law, Affiliated Person, Form ADV, private fund, Master-Feeder Structure, Side-by-Side Structure, Specialized Feeder, Outstanding Voting Securities, pooled investment vehicle, limited partnership, Limited Liability Company, Independent Verification of Assets Requirement, general partner, Nominal Capital Account, Limited Partner, Instrument, total return swap, Record Owner, Equity Security, prudential regulators, Secretary of the Treasury, Security-Based Swap, Staff Responses to Questions About the Custody Rule, Question VI.11, Voting Rights, Redemption, Transparency Rights, regulatory assets under management, de minimis exemption, Regulatory Assets, separate account structure, Gross Assets Calculation, Fair Value, valuation methodology,

MFA Comments to the U.K. Hedge Fund Working Group’s Consultation Paper12.14.07


Today, MFA submitted the following response letter to the U.K. Hedge Fund Working Group on its Consultation Paper. The overall […]

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Topics: Hedge Fund Working Group consultation paper, HFWG, Sound Practices for Hedge Fund Managers, United Kingdom, global relevance, global alternative investment industry, hedge funds, funds of funds, managed futures funds, jurisdictional requirements, fund governing bodies, Third Party Administrators, board of directors, U.S. based funds, net asset value, compliance, Comply or Explain, managers, investors, counterparties, bright line test, Fund Governing Body, President's Working Group on Private Pools of Capital (PWG), Securities and Exchange Commission (SEC), offshore, non-U.S. exchanges, Irish Stock Exchange, Luxembourg Stock Exchange, regulatory implicationsm Websites, segregation, potential conflicts, third parties, Investment Policy, Risk Disclosure, potential liability, Performance Measurement Disclosure, non-marketable, illiquid securities, portfolio, marketable securities, valuation determinations, Chartered Financial Analyst Institute, Global Investment Performance Standards, independent valuation services providers, portfolio management, independent third parties, independent in-house functions, Difficult-to-Value Assets, exchange traded posistions, uncertainity, Fair Value, fire sale, Disclosure, market price, audited annual accounts, side pocket, market risk, stress testing, Governance of Operational Risk, conflicts of interest, compliance procedures, client confidentiality, Outsourcing Risk, service legal agreement, Key Performance indicators (KPis) Fund Governance Disclosure, spectrum, Market Abuse, Insider Dealing, inside information, disclosure thresholds, U.S. securities law, UK, AML, side letters, commercial terms, reconciliation errors, valuation, legal risks, regulatory risks, trade association, board of trustees, investor groups, Regulators, Lenders/Prime Brokers/Dealers, OTC market particpants, cross-market particpant working group, OTC derivatives transactions, Federal Reserve Bank of New York for OTC equity derivatives, OTC electronic transaction posistions, price sources, cherry picking, performance fee, scenario analyses, counterparty risk, netting agreements, collateral agreements, collateral calls/two way collateral posting, soft limits, Model Risk, Key man risk, one-stop shop, prime brokers, Derivative posistions, Borrowed Stock, exposure, stock lender, proxy voting policy, Alternative Investment Management Association, AIMA,

MFA Comments to IOSCO on Consultation Report on Principles for the Valuation of Hedge Fund Portfolios06.21.07


MFA submits comment letter to IOSCO on its Consultation Report on Principles for the Valuation of Hedge Fund Portfolios.

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Topics: IOSCO IOSCO's 2007 32nd Annual Conference, Mumbai., India, valuation of investments, hedge funds, global set of principles, conflicts of interest, investors, IOSCO Report, Investment Portfolios, hedge fund management, hedge fund managers, global alternative investment industry, advocate, absolute return strategies, public, private sector, United States, Securities and Exchange Committee, SEC, Commodity Futures Trading Commision, CFTC, Federal Reserve, Department of the Treasury, state agencies, Congress, major dealers, derivative market practices, advisory, government bodies, United Kingdom's Financial Services Authority, FSA, Securities Exchange Board of India, MFA's 2005 Sound Practices, Investor Protection, key market soundness, Management and Internal Trading Controls, Responsibilites to Investors, Valuation Policies and Procedures, Business Continutiy and Disaster Recovery, President's Working Group on Financial Markets, PWG, risk management, internal trading controls, Regulatory Controls, Transactional Practices, business continuity, disaster recovery, valuation, macro-level guidance, operational framework, risk monitoring, U.S. regulatory Filings, anti-money laundering, Checklist for Compliance Manuals, Checklist for Code of Ethics, consistency, independence, transparency, financial instruments, market prices, Instrument, organized exchanges, data vendors, governing body, third parties, mission-critical, Third Party Service Providers, investment portfolio, global capital markets, portfolio strategies, material obstacles, net asset value, NAV, Fair Value, pricing poliies and sources, price validation, financial statement close process,

MFA Submits Comments to IOSCO on Consultation Report on Hedge Funds Offered to Retail Investors05.31.06


MFA Submits Comments to IOSCO’s “Regulatory Environment for Hedge Funds” survey

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Topics: Consultation Report on Hedge Funds Offered to Retail Investors hedge funds, The Regulatory Environment for Hedge Funds, hedge fund industry, alternative investment industry, fund of funds, managed futures funds, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, CFTC, Federal Reserve System, Department of the Treasury, United States Congress, MFA's Sound Practices for Hedge Fund Managers, MFA's 2005 Sound Practices, dealers, credit derivatives, investor, valuation, regulation, single-manager hedge funds, IOSCO, International Organization of Securities Commissions, IOSCO Technical Committe Standing Committee on Investment Management, SC5 2003 Report, Federal Securities Laws, hedge fund managers, Code of Ethics, pooled investment vehicle, private equity, venture capital, real estate funds, sophisticated investors, institutional investors, due diligence, absolute return strategies, FTSE-250, S&P 500, investment advisers, registered investment companies, RICs, private fund, client, Look Through, investment company, assets under management, AUM, commodity pool operator, CPO, futures, options contracts, futures exchange, commodity trading advisor, CTA, National Futures Association, NFA, reporting requirements, Regulation D, accredited investors, registered public offerings, implications of the growth of hedge funds, fraudulent behavior, Senate Banking Subcommittee on Securities, Fair Value, net asset value, NAV, pricing, illiquid investments, derivatives, hard-to-v, side pocket, conflict of interest,

MFA Submits Comment Letter to FSA Regarding Discussion Paper “Hedge funds: A discussion of risk and regulatory engagement”10.28.05


MFA Comment Letter to UK’s FSA re: Discussion Paper on Hedge Funds

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Topics: Financial Services Authority FSA, hedge funds, risk, regulatory oversight, alternative investment industry, United Kingdom, fund of funds, managed futures funds, hedge fund industry, assets under management, AUM, United States, Canada, New York, London, Delaware, soft commission, short selling, Securities and Exchange Commission, SEC, hedge fund adviser, Roel Campos, hedge fund managers, market participants, self-regulatory organization, SRO, regulatory framework, offshore, regulatory arbitrage, liquidity, valuation, derivatives, derivatives transactions, Fraud, implications of the growth of hedge funds, MFA's Sound Practices for Hedge Fund Managers, MFA's 2005 Sound Practices, AIMA, Alternative Investment Management Association, internal trading controls, investors, Transactional Practices, single-manager hedge funds, President's Working Group on Financial Markets, PWG, Sound Practices, risk management, internal controls, segregation, collateral, Department of the Treasury, Board of Governors of the Federal Reserve System, Ben Bernanke, Commodity Futures Trading Commission, CFTC, Guide to Sound Practices for European Hedge Fund Managers, industry-led initiatives, counterparty risk management policy, Policy Makers, pooled investment vehicle, private equity, venture capital, real estate funds, bank, investment bank, private funds, retail funds, sophisticated investors, net worth, due diligence, absolute return strategies, S&P 500, FTSE-250, Long Term Capital Management, financial instrument, leverage, global financial marketplace, market risk, credit risk, liquidity risk, risk position, portfolio manager, stress testing, cash management, Cash Flow, drawdown, Redemption, counterparties, International Organization of Securities Commissions, IOSCO, hedge fund administrator, GAAP, generally accepted accounting principles, Fair Value, net asset value, NAV, illiquidity, hard-to-value, side pockets, absolute return, Portfolio Diversification, institutional investors, high net worth requirements, price discovery, Absolute Return Magazine, Robert Jaeger, operational risk, disclosures, Greenwich Roundtable, credit derivatives, derivatives markets, International Swaps and Dealers Association, ISDA, novation protocol, dealers, novations, trade associations, Office of Risk Assessment, compliance burden,
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