MFA Comment Letters

Topic: harmonization

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 Submits Letter and White Paper on Protection of Non-Public, Sensitive, and Proprietary Information by FSOC Members05.22.13


MFA submitted a cover letter and white paper to each member of the Financial Stability Oversight Council (FSOC) on the […]

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Topics: FSOC Financial Stability Oversight Council, market structure, SEC, CFTC, CTA, CPO, Securities and Exchange Commission, Commodity Futures Trading Commission, Dodd-Frank Act, market participants, financial stability, Managed Funds Association, Department of the Treasury, Board of Governors of the Federal Reserve System, Office of the Comptroller of the Currency, Consumer Financial Protection Bureau, Federal Deposit Insurance Corporation, FDIC, Federal Housing Finance Agency, National Credit Union Administration, Office of Financial Research, Federal Insurance Office, data collection, research, trade sectrets, liquidation, investment advisers, Richard H. Baker, U.S. House of Representatives Committee on Financial Services, data repositories, Trading Activities, harmonization, U.S. securities law, commodity pool operator, commodity trading advisor, self-regulatory organization, SRO, intermediary, broker-dealer, futures commission merchants, FCM, swap data repository, SDR, clearinghouses, systemic risk, Form PF, Form CPO-PQR, Form CTA-PR, registered investment adviser, adviser registration, substituted compliance, confidentiality, inspector general reports, Reverse Engineered, Trade Secrets, front running, SEC Office of Inspector General, Andrei Kirilenko, Adam Clark-Joseph, Jaksa Cvitanic, high frequency trading, National Institute of Standards and Technology, NIST, reporting, President Obama, information security program, Rulemaking, Council of Inspectors General on Financial Oversight, CIGFO, Security-Based Swap Data Repositories, SBSDR, Designated Clearing Organizations, DCO, Richard A. Shilts, legal entity identifiers,

MFA and AIMA Submit Joint Letter to ESMA in Response to Call for Evidence on Short Selling Regulation03.15.13


MFA and AIMA jointly submitted a comment letter to ESMA responding to its Call for Evidence regarding its evaluation of […]

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Topics: ESMA European Securities and Markets Authority, AIMA, Alternative Investment Management Association, European Parliament, Council of the European Union, short selling, credit default swap, CDS, short selling regulation, Europe, equity, assets under management, AUM, harmonization, competent authorities, reporting requirements, short positions, European Commission, operational challenges, short selling bans, market participants, securities, sovereign issuer, capital, liquidity, price discovery, market distortions, hedging, risk, sovereign debt, Latvia, bond, sovereign bonds, EU Member State, futures, futures market, public disclosure, stock, reverse engineer, efficiency, short squeeze, volatility, reporting obligation, T+1 reporting, hedge funds, price formation, corporate issuer, Lehman Brothers, duration, delta, derivatives, share capital, index derivatives, AIFMD, MiFID, EMIR, net short position, Belgium, Finland, Germany, Netherlands, BaFin, United Kingdom, Commissione Nazionale per le Societa e la Borsa, Committee of European Securities Regulators, CESR, issued share capital, T+2, Bundesanstalt fur Finanzdienstleistungsaufsicht, settlement, locate, prime broker, index, third party managers, technical standards, non-EU investment firms, extraterritoriality, reasonable expectation, uncovered sovereign CDS, eurozone, mark-to-market, single-name CDS, France, Spain, Italy, trading volume, Steven Maijoor, bid-ask spreads, price efficiency, derivative instrument, depositary receipts, London Stock Exchange, PRNewswire, Stock Exchange Daily Official List, compliance, market disruption, interpretive guidance,

MFA Submits Comment Letter in Response to Basel-IOSCO’s Consultative Document on Margin Requirements for Non-Cleared Derivatives09.28.12


MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision […]

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Topics: Basel Committee on Banking Supervision International Organization of Securities Commissions, IOSCO, margin, margin requirements, non-centrally cleared derivatives transactions, Working Group on Margining Requirements, derivatives, derivatives markets, margining, clearing, market participants, central clearing, risk management, initial margin, variation margin, best practices, liquidity, mandatory clearing, bilateral exchange, buy-side firms, segregated account, custodian accounts, hedge, hedge funds, netting, eligible collateral, portfolio margining, over-collateralization, mutually offsetting transactions, margin threshold, harmonization, uniformity, non-compliance, regulatory arbitrage, market advantage, phase-in period, implementation timeline, non-cleared derivatives, regulatory authorities, foreign exchange, swaps, forwards, risk profile, market infrastructures, liquidity characteristics, currency, Denominated in G7 Currencies, G7, cleared derivatives, systemic risk, systemic importance, systemically important, systemically important non-financial firm, liquidity costs, unlevel playing field, transparency, SIFI, systemic risk level, credit, unsecured credit extension, minimum transfer amount, MTA, prudentially regulated financial counterparties, two-way margining, standard practice, credit risk, clearing house, bilateral exchange of variation margin, market liquidity, credit default swap, CDS, novation, remaining party, party stepping out, party stepping in, novating parties, market value, Regulators, novation arrangements, liquidity mechanism, asset classes, liquidation, Dodd-Frank Act, European Union, EU, United States, ISDA, International Swaps and Derivatives Association, replacement transaction, market practices, cross-product master netting agreements, risk offsets, financial instruments, U.S. Treasury futures, Eurodollar futures, non-cleared interest rate swaps, repurchase agreements, correlated financial instruments, quantitative impact study, Portfolios, central counterparty, CCP, hedged portfolios, prudential regulators, risk characteristics, risk/reward profile, diversification, concentration limits, haircuts, segregation, third-party segregation, re-hypothecation, cost mitigation, Commodity Futures Trading Commission, CFTC, swap dealers, major swap participants, equities, delta, interest rates, CDS spreads, notional value, commodities,