MFA Comment Letters

Topic: New York Stock Exchange

MFA and AIMA Submit Letter on Canadian Early Warning Reporting System07.12.13


MFA and AIMA submitted a letter to Canadian regulators in response to proposed amendments to Canada’s Early Warning System and […]

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Topics: Canada AIMA, MFA, Alternative Investment Management Association, Canadian Early Warning Reporting System, EWR, British Columbia Securities Commission, Alberta Securities Commission, Financial and Consumer Affairs Authority of Saskatchewan, Manitoba Securities Commission, Ontario Securities Commission, Autorite des Marches Financiers, New Brunswick Securities Commission, Superintendent of Securities Prince Edward Island, Nova Scotia Securities Commission, Securities Commission of Newfoundland and Labrador, Superintendent of Securities Yukon Territory, Superintendent of Securities Northwest Territories, Superintendent of Securities Nunavut, United Kingdom, transparency, securities law, Andrew Vollmer, Paul Wolfson, Alternative Monthly Reporting, shareholders, total return swaps, contracts for difference, derivatives, OTC derivatives, eligible institutional investor, institutional investors, board of directors, regulatory regime, capital markets, Ronald Gilson, Jeffrey Gordon, Brian Cheffins, Nickolay Gantchev, Chotibhak Jotikasthira, activist hedge fund, Hedge Funds Review, Canadian Coalition for Good Governance, National Bureau of Economic Research, corporate governance, remuneration, return on assets, performance, Kimber Report, investor reporting, reporting, non-objecting beneficial owners, beneficial owners, TSX, TSX Venture Exchange, System for Electronic Document Analysis and Retrieval, SEDAR, System for Insider Data on Insiders, SEDI, Yahoo!Finance, Stockhouse, Seeking Alpha, Reuters, StockCharts, Google Finance, Morningstar, Australia, Securities and Exchange Commission, SEC, disclosure and transparency rules, voting shares, equity securities, Financial Conduct Authority, FCA, London Stock Exchange, Issuer, Counterparty, relevant interests, Australian Securities and Investments Commission, ASIC, qualified investors, banks, broker-dealer, investment company, Bank of Canada, hedge funds, New York Stock Exchange, Australian Stock Exchange, liquidity, TMX Group Limited, Canada Pension Plan Investment Board, Ontario Teachers' Pension Plan, OMERS Administration Corporation, British Columbia Investment Management Corporation, The Caisse de depot et placement du Quebec, Alberta Investment Management Corporation, Ward Phillips & Vineberg LLP, confidentiality, cost-benefit analysis, disclosures, hedging, TELUS Corporation,

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,

Comment Letter to SEC Responding to Concept Release on Equity Market Structure05.07.10


MFA submitted a letter to the SEC in response to its request for comments on its Equity Market Structure Concept […]

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Topics: Securities and Exchange Commission SEC, Equity Market Structure, order handling rules, regulation ATS, decimalization, Regulation NMS, institutional investors, retail investors, liquidity, bid-ask spreads, transaction costs, technology, non-public trading, risk management, broker dealers, capital formation, long-term investors, short-term traders, registered investment advisers, private investment pools, pensions, endowments, foundations, insurance companies, direct market access, sponsored access, low latency technology, high frequency trading, HFT, automated trading, investor confidence, trading volume, order cancellations, market maker, specialist quotes, algorithm, quantitative strategies, global financial crisis, frontrunning, order anticipation, public information, momentum ignition, dark pools, Office of Economic Analysis, post-trade execution, National Market System, electronic communication networks, ECN, alternative trading systems, Intermarket Trading System Plan, ITS, Nasdaq, electronically accessibel quotes, New York Stock Exchange, NYSE, U.S. Department of Justice, National Association of Securities Dealers Inc., proprietary trading, electronic trading desks, inventory risks, inter-market arbitrage, price discovery, spreads, fees, execution speed, market depth, efficiency, transparency, Japan, Germany, United Kingdom, France, hedging, Market Crash of 1987, asset classes, fixed income, buyers, sellers, market fragmentation, investment time horizon, capital allocation, mutual fund, trading desk, competitive barriers, U.S Treasury bonds, Treasury ETF, large cap stocks, small cap stocks, securities lending, quote flickering, phantom liquidity, cancellation rate, limit orders, order protection rule, market consolidation, Designated Market Maker, volatility, short selling, market color, trends, sector change, co-location, price swings, pinging, upstairs market, post-trade transparency, connectivity vendors,

MFA Comments to SEC on Interim Final Temporary Amendments to Regulation SHO12.15.08


MFA sent a letter to the SEC providing comments to the Commission’s interim final temporary rule on amendments to Reg […]

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Topics: Securities and Exchange Commission SEC, emergency orders, short selling, manipulative naked short selling, market dislocations, market participants, liquidity, public interest, efficiency, competition, capital formation, Financial Industry Regulatory Authority, FINRA, broker-dealer, naked short selling, pricing efficiency, Short Selling Activity in Financial Stocks, SEC July 15 Emergency Order, Arturo Bris, European Corporate Governance Institute, Yale International Center for Finance, three-day settlement cycle, capital raising, risk management, derivatives hedging strategies, hedging, distressed companies, capital, market risk, "delta" hedge, volatility, public companies, fails to deliver, securities, close-out, Voting Rights, prime broker, algorithmic trading, automated trading, manual trading, short selling regulation, clearing, settlement, uptick rule, sell-side firms, buy-side firms, hard to borrow shares, easy to borrow shares, locate, threshold securities list, threshold securities, self-regulatory organization, SRO, short positions, short squeeze, operational efficiency, bid-ask spreads, options, market maker, long sales, market efficiency, market liquidity, delivery, securities depositaries, custodian banks, executing brokers, Continuous Net Settlement, National Securities Clearing Corporation, NSCC, clearing agency, settlement date, market distortions, order to purchase, artificial buying pressure, borrowing costs, G19, G19 securities, Wall St. Journal, regulatory efficiencies, mandatory close-out, T+5, T+2, T+4, pre-fail credit, NYSE, New York Stock Exchange, debt securities, arrangement to borrow,

MFA Submits Joint Letter to SEC on Proposed Revisions to Rules to Shorten Restricted Security Holding Periods09.21.07


MFA submits comments to the SEC in a joint letter with the Securities Industry and Financial Markets Association and the […]

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Topics: Securities and Exchange Commission SEC, Securities Industry and Financial Markets Association, SIFMA, International Swaps and Derivatives Association, ISDA, securities, banks, asset managers, privately negotiated derivatives industry, hedge funds, managed futures funds, underwriter, security-holders, broker dealers, affiliates, Issuer, public markets, Investor Protections, public resales, Holding Period, liquidity, capital, tolling, restricted security holding periods, shell companies, equity securities, hedging activities, transaction, Securities Industry Association, Jesse M. Brill, SIA, brokerage firms, institutional investors, derivative positions, holding periods, hedging periods, long posistion, long-equivalent, short, short-equivalent, disaster recovery, business continuity, prime brokers, clearing brokers, Portfolios, risk management strategies, account managers, trading desks, institutional holders, significant costs, compliance, pilot basis, Net Notional Amounts, safe harbor, private capital formation, short call option posistion, shares, relevant unit, Aggression, Single Trading Strategy, business units, buy-side, sell side, information sharing, regulatory requirements, client confidentiality, holder, monitor, record, track, verify, market, client driven, Partial Hedging, doctrine of fungibility, convertible debt, noncovertible debt, restricted debt securities, credit exposures, Goldman Sachs & Co., pre-paid forward contracts, Goldman Sachs II, forward and option contractsm sales, Baskets of Securities or Indices, basket, index, Nonconvertible Debt Securities, Fixed Income Exchange, class relief, Powershares Exchange-Traded Fund Trust (ETF), exchange traded index funds (ETF), S&P 500 securities, New York Stock Exchange, Chicago Board Options exchange, Transfer Restrictions, bids, resecuritization, domestic issuers, Reasonale Belief, Reliance on Represenatons, internal information barrier, transparency, preferred stock, asset-backed securities, inter-dealer quotation systems, VWAP Trades, volume-weighted average prices, qualified institutional buyers, usual and customary, executioms, market makers, volume limitations, FINRA/NASD rule 2320, aggregate resales, Form 144, Form 4, restricted security holders, seller, Form D filing, unaffiliated seller, director, executive officer, ten percent beneficial owner, multiple accounts, portfolio managers, Restrictive legends, de-legending, private placement, Staff Interpretive Posistions, Cashless Exercises, deminimis exercise prices, nominal exercise prices, pennies per share, Former Shell Company, Form 10 information, over-the-counter derivatives, OTC derivatives, fund of funds, credit default swap, CDS, alternative trading systems, actual knowledge standard, FINRA, Financial Industry Regulatory Authority,

MFA Comments to IOSCO’s Call for Views on Issues That Could Be Addressed by IOSCO on Funds of Hedge Funds08.03.07


MFA submits comments in response to IOSCO’s “Call for Views on Issues that Could Be Addressed by IOSCO on Funds […]

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Topics: IOSCO FOHF Report, Investor Protection Issues, U.S. Funds of Hedge Funds, investment companies, Exemption, Disclosure, recordkeeping requirements, Commodity Pools, global alternative investment industry, hedge funds, managed futures funds, policymakers, absolute return strategies, private sector initiatives, hedge fund industry, United States, public sector, Federal Reserve, state agencies, Congress, private sector, major dealers, derivative market practices, international advisory and government bodies, United Kingdom's Financial Services Authority, Securities Exchange Board of India, retail investors, Full Part 4 Funds, Full Part 4 CPOs, Company Act FOHFs, IOSCO Technical Committe Standing Committee on Investment Management, retail investors' increased investment in FOHF's, IOSCO Report, Retail investment, retail market, regulatory regime, offering disclosure regime, advertising rules, Investor Protection, disclosure requirements, senior securities, management agreements, transactions, broker dealers, Financial Industry Regulatroy Authority, NASD, New York Stock Exchange, Investor Suitability, Manner of Offering, accredited investors, securities, private offering exemption, safe harbor, Public Offering, offering, mass mailings, General Solicitation, advertisement, open-end investment companies, mutual, liquidity, shareholders, periodic tender offers, high net worth requirements, qualified clients, natural person, adviser, net worth, initial investment requirements, retail funds, disclosure documents, compliance, compliance examinations, Company Act Registration, investment company, board members, interested persons, counsel, annual self-assessment, executive session, assets, bank, custody, broker-dealer, bank custodians, chief compliance officer, compliance policies and procedures, Federal Securities Laws, codes of ethics, fraudulent or manipulative practices, personal securities transactions, principal transactions, underlying fraud, outstanding voting, Affiliated Person, non-voting interests, agency transactions, asset coverage, company obligations, shares, dividends, borrowings, derivative instruments, advisory contracts, diversification, real estate, shareholder approval, breaches of fiduciary duty, compensation, registration statements, Form N-SAR, principal executive, principal financial officers, material fact, record keeping requirements, for cause examinations, sweep examinations, adviser operations, Subscription Agreement, verbatim risk of loss disclosure statements, table of contents, business background, risk factors, volatility, leverage, counterparty creditworthiness, commodities, margin obligations, fees, expenses, break-even chart, conflicts of interest, soft dollar, directed brokerage arrangements, futures brokers, tansferability and redemption rights, tax, liability, investor's capital contribution, undistributed profits, financial reporting to investors, Annual Report, Plain English Requirements, NFA Notice I-07-25, state securities regulators, statement of additional information, Company Act Disclosure Requirements, closed-end investment companies, Form N-2, prospectus, fee table, sales loads, offering price, dividend reinvestment, cash purchase plan fees, transaction fees, net assets, common shares, management fees, interest payments, borrowed funds, acquired fund fees, total annual expenses, initial investment, a 5% annual return, rask factors, public trading market, portfolio managers, Plain English Principles, glossaries, technical terms, administrators, custodians, affiliated broker, tax consequences, net asset value, capital stock, voting, liquidation, material pending legal proceedings, committee structure, ownership of shares, family of investment companies, proxy voting, independent registered public accounting firm, performance fees, securities transactions, tax status, offering prive, underwriters, legends, high risk, annual financial statements, independent public accountant, periodic statements, U.S. generally acceped accounting principles, accrual method of accounting, an oath or affirmation, unaudited semi-annual reports, fiscal period, Portfolio Holdings, advisory contract, Form N-CSR, Senior officer code of ethics, audit committee financial expert, audit, audit-related, share repurchases, U.S. GAAP, total return, futures professionals, promotional material, prospective investors, cherry picking, IOSCO Technical Committee, Securities and Exchange Commission, SEC, CFTC, Commodity Futures Trading Commission, commodity pool operator, CPO, fund of funds, Department of the Treasury, MFA's Sound Practices for Hedge Fund Managers, National Futures Association, NFA, FINRA,
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