MFA Comment Letters

Topic: institutional investor

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 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,

Comment Letter on IOSCO’s Consultation Report on ‘Regulatory Issues Raised by the Impact of Technological Changes on Market Integrity and Efficiency,’08.12.11


MFA submitted comments to IOSCO on its consultation report on Regulatory Issues Raised by the Impact of Technological Changes on […]

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Topics: Mr. Werner Bijkerk International Organization of Securities Commissions, Spain, Technical Committee of the International Organization of Securities Commissions, OSCO, Regulatory Issues Raised by the Impact of Technological Change on Market Integrity and Efficiency, Consultation Report, high frequency trading, HFT, market trends, technological developments, institutional investors, pensions, endowments, foundations, insurance companies, market liquidity, Economic Growth, market efficiencies, market access, market information, transaction fees, order execution, Technical Committee, empirical data, algorithmic trading, trading strategies, Gomber, Arndt, Lutat, Uhle, transaction delivery, Peter Gomber, electronic markets, computer programs, monopolies, proprietary, investment time horizons, low latency, broker dealers, sponsored access, spreads, fees, execution speed, market depth, efficiency, transparency, pricing reliability, TAGG Group, fixed commission rates, Schwab, E-Trade, Fidelity, TD Ameritrade, passive, long-term, mutual funds, algorithms, proprietary trading tools, executing brokers, third party vendors, buy-side brokers, fiduciary obligation, educational campaigns, Flash Crash of May 6, 2010, flash crash, market dislocations, Dow Jones Industrial Average, Market Break of 1962, Securities Exchange Commission, SEC, 1963 Special Study of the Securities Markets, 1963 Special Study, New York Stock Exchange, dark pools, wait-and-see, single-stock circuit breakers, CFTC, Joint Advisory Committee on Emerging Regulatory Issues, bid-ask spreads, Thomson, NBBO, Barclays Capital Equity Research, EU, Japan, Germany, UK, France, Nasdaq, Merrill Lynch, Goldman Sachs, LaBranche, Barclays Plc., institutional investor, Financial Crisis of 2008, Rosenblatt Securities, AIG, Fannie Mae, Freddie Mac, Washington Mutual, Market Crash of 1987, intermediary firm, DEA, circuit breakers, limit-up/limit-down systems, erroneous trades, Elizabeth Murphy, Joint Industry Limit Up-Limit Down Proposal, two-sided displayed quotes, oversight, affirmative stock locate framework, ETFs, quote stuffing, order-to-trade ratios, co-location services, standardize disclosure, connectivity, TABB Group, effective spreads in European equities, Division of Risk, Strategy and Innovation memorandum, threshold securities, National Securities Clearing Corporation, NSCC, Office of Markets in the Division of Risk, Strategy and Financial Innovation,

MFA Comments to SEC on Pay to Play Proposal10.06.09


MFA submitted a letter to the SEC today in response to its proposal to, among other things, restrict political contributions […]

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Topics: Securities and Exchange Commission SEC, pay to play practices, government assets, political contributions, investment adviser, investment management services, government entities, third party placement agents, municipal securities, Municipal Securities Rulemaking Board, MSRB, investment management industry, municipal underwritings, municipal securities underwriters, municipal securities professional, chief compliance officer, American Bar Association, Committee on Federal Regulation of the American Bar Association, state and local entities, legal authorities, compliance burden, agency, authority, instrumentality of the State, plan, program, pool of assets, political action committee, inauguration or transition committee, local or state political party, Foundation, charitable institution, government official, Regulators, covered associates, general partner, executive officer, Broker, Dealer, municipal securities business, municipal securities representative, municipal securities principals, sales principals, principal business unit, look-back provision, look-back period, securities firms, academic institutions, chilling effect, soliciting, personal political activities, beneficial owners, family members of covered associates, portfolio manager, written compliance policies and procedures, pre-approval procedures, disproportionately severe punishment, private fund, limited partnership, redemption rights, public pension plans, interest, contractual rights and obligations, management fees, liquidity, fund assets, redemption requests, investment services, fiduciary duty, assets, compensation arrangements, institutional investor, incentive fee structure, backward-looking provisions, operational challenges, compliance procedures, pooled investment vehicle, de minimi exception, returned contribution, Inadvertent Violation, inadvertent contribution, covered investment pool, registered investment companies, publicly offered securities, fund of funds, direct investment, platform arrangement, direct investors, third party placement agent, pension, third party solicitors, placement agent, hedge fund managers, hedge funds, offshore managers, marketing activities, broker-dealer, requests for proposals, due diligence, investment advisory services, investment techniques, investment objectives, risk management, anti-competitive effects, California Public Employees' Retirement System, CalPERS, CalSTRS, Los Angeles County Employees' Retirement System, Los Angeles City Employees' Retirement System, New Mexico Educational Retirement Board, Teacher Retirement System of Texas, Pennsylvania Public School Employees' Retirement System, Pennsylvania State Employment Retirement System, Connecticut, Massachusetts, Oklahoma, Washington, New York State Common Retirement Fund, New York City Employees' Retirement System, New Mexico Investment Council, New York, Illinois, pay to play scandals, Disclosure, transparency, state and federal laws, regulations, registration, cash solicitation, Wall St. Journal, code of ethics rule, compliance costs, Form ADV, registered investment adviser, unregistered adviser, pre-approval policies, affiliated broker-dealer,