MFA Comment Letters

Topic: performance fees

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 Responding to the Financial Stability Oversight Council’s Advance Notice and Request for Comment on the Criteria for Designating a Nonbank Financial Company as Systemically Important.11.05.10


MFA submitted a comment letter to the Financial Stability Oversight Council in response to the Councils advance notice and request […]

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Topics: Systemically Important Institutions Financial Stability Oversight Council, FSOC, Nonbank Financial Company, Systemically Important Financial Companies, market participants, Systemic Risk Monitoring, Board of Governors, Federal Reserve System, Systemically Relevant Firms, Congress, "too big to fail, U.S. Financial Stability, hedge funds, Financial Market Participants, counterparty risk management, banks, broker-dealer, hedge fund industry, collateral, Borrowing, counterparties, capital markets, financial system, global mutual fund industry, U.S. Banking Industry, systemic risk, assets under management, leverage, Colombia University, Investment Company Institute, Federal Financial Institutions Examination Council, BofA Merrill Lynch, risk monitoring, due diligence, Collateral Posting, credit exposure, Structure of the Industry, Financial Assets, investment portfolio, sophisticated investors, ultra-high net worth individuals, retail investors, diversified portfolio, Liquidity Restrictions, Periods of Redemption, Redemptions, gates, Side Pocket Vehicles, Highly Illiquid Assets, alignment of interests, performance fees, high water marks, risk-adjusted returns, Legally Distinct Funds, Common Adviser, financial institutions, insurance companies, Long Term Capital Managment, LTCM, Position Size, Inadequate Counterparty Risk, leverage ratio, OTC Derivatives Trades, OTC, Counterparty Risk Management Policy Group, Fed Chairman Bernanke, Securities Exchange Commission, SEC, regulatory regime, over-the-counter derivatives, Standardized Transactions, swap dealers, major swap participants, CFTC, Cleared Transaction, Uncleared Transaction, margin requirements, prime brokerage, Short-Term Funding, overnight borrowing, asset mix, off-balance sheet exposures, bank holding companies, Equity Capital Stability, FDIC, FDIC deposit insurance, Debt Guarantees, Government-Issed Charter, Government-Funded Capital, Troubled Asset Relief Program, TARP, Federal Reserve's Discount Window,

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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