MFA Comment Letters

Topic: no-action letters

MFA Petitions the CFTC to Exclude Certain Employee Pools from the Definition of “Pool”08.30.12


MFA petitioned the CFTC to provide an exclusion from the definition of commodity “pool” for certain internally owned entities, including […]

Comment Letter to the SEC on Establishment of a Registration Regime for Municipal Advisors as Required by the Dodd-Frank Act.02.22.11


MFA submitted a comment letter to the SEC in response to its proposal to establish a registration regime for municipal […]

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Topics: Securities and Exchange Commission SEC, municipal advisors, duplicative registration, investment advisers, commodity trading advisors, CTAs, pooled investment vehicles, municipal financial products, municipal securities, guaranteed investment contracts, investment strategies, municipal escrow investments, pools of assets, pooled investment vehicle, municipal advisor, primary investors, private fund managers, solicitation, common control, third-party solicitor, SEC regulation, CFTC regulation, regulated persons, registered broker-dealer, pay to play rule, SEC-registered entities, registered investment advisers, registered CTAs, municipal advisory activities, municipal derivatives, commodity for future delivery, option, securities futures product, Security-Based Swap, bank deposits, investment advisory services, ancillary services, registered advisor, regular oversight, state-registered investment advisors, exempt reporting advisers, state entity, self-regulatory entity, state securities commission, mid-sized adviser, participating affiliate agreements, no-action letters, affiliate letters, SEC resources, multi-jurisdictional advisory firms, venture capital funds, private fund advisors, foreign private advisers, SEC No-Action Letter, Uniao de Banco de Brasileiros, Kleinwort Benson Investment Management Limited, Murray Johnstone Holdings Limited, ABN AMRO Bank N.V., Royal Bank of Canada, SEC oversight, transition period for registration, private adviser exemption, Form MA, dually-registered investment advisers, Form ADV,

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 Letter to SEC Chairman Cox Regarding Hedge Fund Transparency and Other Issues04.24.08


MFA President and CEO, Richard H. Baker, met with SEC Chairman Christopher Cox this morning and discussed the topics addressed […]

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Topics: Securities and Exchange Commission SEC, Christopher Cox, alternative investment industry, Policy Makers, Regulators, investors, hedge funds, hedge fund offerings, transparency, hedge fund investors, capital markets, systemic risk, General Solicitation, Ban on General Solicitation and Advertising, General Advertising, safe harbor, Regulation D, hedge fund managers, sophisticated investors, accredited investors, qualified purchasers, private offerings, securities, Protecting Investors: A Half Century of Investment Company Regulation, Division of Investment Management, United States Congress, Implications of the Growth of Hedge Funds Staff Report to the United States Securities and Exchange Commission, Rulemaking, advertising materials, Clover Capital no-action letter, staff guidance, no-action letters, accredited natural person, large accredited investor, Federal Securities Laws, inflation, mutual recognition, Nancy Morris, regulatory barriers, Cross-Border Investments, market participants, transaction costs, global capital markets, financial services industry, Australia, European Union, EU, Canada, broker-dealer, best practices, Sound Practices for Hedge Fund Managers, NYRO OCIE, chief compliance officer, trade associations, Commodity Futures Trading Commission, CFTC, Memorandum of Understanding, public commodity pools, National Futures Association, NFA, Financial Industry Regulatory Authority, FINRA, public commodity pool offerings, futures, futures market, pooled investment vehicle, public offering disclosure requirements, Direct Participation Programs, DPP, annual cap, lifetime cap, offering proceeds, trail commissions, managed futures, brokers,

MFA Letter to Senate Republican Capital Markets Task Force Regarding United States Capital Markets Competitiveness in the Global Financial Services Marketplace02.29.08


MFA submits a comment letter to the Senate Republican Capital Markets Task Force in response to the Task Force’s request […]

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Topics: Senate Republican Capital Markets Task Force United States Congress, capital markets, U.S. Capital Markets, global financial system, regulatory regime, tax, capital formation, capital efficiencies, financial regulatory system, principles-based regulation, Securities and Exchange Commission, SEC, regulation, non-U.S. investors, capital, hedge funds, venture capital funds, oil and gas partnerships, Strategy and Financial Innovation, Investor Protection, Financial Services Roundtable, Blue Print for U.S. Financial Competitiveness, Commodity Futures Trading Commission, CFTC, safe harbor, exchanges, market crisis, market participants, duplicative regulation, public commodity pools, National Futures Association, NFA, Financial Industry Regulatory Authority, FINRA, commodity futures markets, energy commodities, Federal Energy Regulatory Commission, FERC, natural gas futures market, Federal Trade Commission, financial services industry, President's Working Group on Financial Markets, PWG, Department of the Treasury, Secretary of the Treasury, Federal Reserve Board, assets under management, investment advisers, retail investors, prudential regulators, Henry Paulson, Office of Compliance Inspections and Examinations, OCIE, Economic Club of New York, no-action letters, General Solicitation, General Advertising, transparency, Cross-Border, U.S. immigration policies, skilled non-U.S. professional workers, H-1B visa, student visa, harmonization, generally accepted accounting principles, GAAP, International Financial Reporting Standards, IFRS, mutual recognition, Canada, Enron Corporation, Cendant, Financial Services Forum, United Kingdom, European Union, EU, chilling effect, equity markets,
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