MFA Comment Letters

Topic: net asset value

MFA Response to FSA Discussion Paper on Implementation of the AIFMD03.23.12


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Topics: FSA Discussion Paper "Implementation of the Alternative Investment Fund Managers Directive" Financial Services Authority, FSA, Alternative Investment Fund Managers Directive, AIFMD, non-EU AIFM, Member State competent authorities, letter-box entity, MiFID, MiFID firm, AIFMD firm, retail customers, professional investors, remuneration provisions, CRD3 framework, functional and hierarchal independence, risk management, internationally coordinated approach to reporting, European Securities and Markets Authority, ESMA, single AIFM, family relationship, family investment vehicle, UK AIFM, preferential treatment, side letters, retail consumers, FSA Principles for Business, FCA, UCITS Directive, retail investors, EU Passport, FCA Approach Document, conflicts of interest, SYSC 10 of the FSA Handbook, remuneration guidelines, MiFID portfolio managers, tier 4 firm, FSA Remuneration Code, compliance function, audit function, proportionality principle, regulatory requirements, regulatory risks, chief compliance officer, functional and hierarchical separation, portfolio management, portfolio management personnel, interest alignment, qualitative risk limit, UCITS investors, institutional investors, leverage, NAV, third country, Final Advice on the AIFMD, third country managers, capital requirements, PII requirements, IPRU (INV), professional indemnity insurance, professional negligence, internally managed AIF, CAD-defined terms, valuation procedures, external valuer, net asset value, limited partnership, hedge funds, NAV per share, liquidity requirements, redemption terms, less than fully invested, risk/return profile, net assets under management, investor capital, Value at Risk, VaR methodology, European Central Bank, foreign exchange, interest rate risk, EUR denominated bonds, portfolio risk, hedging arragements, CESR Guidelines on Risk Management and the Calculation of Global Exposure and Coutnerparty Risk for UCITS, CDS, Advanced Method, QIS disclosure requirements, prime brokers, exchanges, swap data warehouses, Dodd-Frank Act, Securities and Exchange Commission, SEC, Form PF, proprietary business information, depositary, unregulated CIS, segregated account, valuation oversight duties, depositary liability, marketing, reverse solicitation process, MiFID investment services, private placement, public offers,

Comment Letter to ESMA on its Draft Technical Advice to the European Commission for Implementing AIFMD09.13.11


MFA submitted comments to ESMA on its consultation on possible implementing measures of the Alternative Investment Fund Managers Directive (AIFMD). […]

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Topics: AIFMD the directive, Level 2, third party managers, European Commission, consultation paper, AIF, UCITS Directive, MiFID, professional investors, retail investors, marketing, counterparties, prime brokers, net asset value, Article 61, AUM, AUM Calculations, mark-to-market, EU investors, sub-investment managers, Dodd-Frank, U.S. Securities and Exchange Commission, SEC, Investment Advisers Act of 1940, Advisers Act, registration, private funds, G-20, international coordination, Article 3(2), Article 9(3), professional indemnity insurance requirements, Gross Method, exposure, leverage, foreign exchange hedging position, interest rate hedging position, Box 93, Box 2, Box 1, NAV, Advanced Method, Box 13, diligence requirement, OTC transaction, securities lending agreement, repurchase agreement, Box 19, Box 29, risk management, risk limits, operational risk, portfolio management, market risk, portfolio risk, liquidity risk, gates, side pockets, redemption policy, depositaries, depositary, bespoke system, Box 78, collateral directive, Box 79, liability standards, Financial Services Authority, FSA, re-hypothecation provisions, Box 81, Box 86, due diligence, sub-custodian, Box 88, segregation, Box 89, omnibus accounts, liability regime, Box 95, Box 99, Value at Risk, VaR, Commitment Method, European Central Bank, ECB, Committee on European Securities Regulators, CESR Guidelines, credit default swap, CDS, remuneration, EU Passport, transparency, Box 106, passport regime, safe-keeping function, confidentiality, proprietary information, systemic risk, semi-annual reporting, collateral, counterparty exposures, Form PF, reporting period, generally accepted accounting principles (GAAP), Level 2 inputs, Level 3 inputs, valuation agents, underwriters, unobservable,

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,

Comment Letter to the Department of Labor in Response to the Departments Proposed Rule to Amend the Definition of Fiduciary Under ERISA02.03.11


MFA submitted a comment letter to the Department of Labor in response to the Departments proposed rule to amend the […]

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Topics: Employee Benefits Security Administration Department of Labor, DOL, ERISA, alternative investment vehicles, hedge funds, diversification, risk management, equity markets, fixed income markets, Joseph Dear, California Public Employees' Retirement System, Senate Banking Subcommittee on Securities, Insurance and Investment, pension fund, rate of return, fee structure, performance fee, total returns, hedge fund managers, risk-adjusted returns, high water marks, government safety new, pooled investment funds, Congress, Securities and Exchange Commission, SEC, Commodity Futures and Exchange Commission, CFTC, non-plan asset funds, plan asset vehicles, general partner, DOL regulations, equity securities, plan assets, market concern, Investor Protection, private investment fund, principal underwriter, fiduciary, appraisals, pricing services, custodians, appraisers, managing member, Internal Revenue Code, pooled investment vehicles, fiduciary liability insurance. prime brokerage, daily mark, swap counterparty, fund administration agreements, asset-based fee compensation, prohibited transaction provisions, net asset value, hard-to-value, private equity holdings, real estate holdings, side-pocket investments, appraisal of property, investment advisers, valuation firm, hedge fund manager, private pension, good faith estimate, may be considered standard, significantly influence standard, ERISA fiduciaries, mutual understanding, valuation of assets, "may be considered" advice, risk appetites, tailored advice, pooled investment fund, exemption applications, transaction reversal, excise taxes, selling exception, due diligence, adverse, marketing services, impartial investment advice, purchaser, seller, bilateral agreement, default, derivative markets, short sales, options, structured products, futures, settlement accommodations, overdraft coverage, inadvertent fiduciary status, pooled vehicle, market color, prime brokers, general partners,

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 […]