MFA Comment Letters

Topic: pooled investment vehicle

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 SEC’s Proposal to Implement Amendments to the Advisers Act Contained in Title IV of the Dodd-Frank Act01.24.11


MFA submitted a comment letter todayto the SEC on its proposal to implement amendments to the Advisers Act contained in […]

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Topics: Securities and Exchange Commission De Minimis Amount, Investment Management, Richard H. Baker, Hearing on Industry Perspectives on the Obama Administration's Financial Regulatory Reform Proposals, Committee on Financial Services, U.S. House of Representatives, venture capital funds, private fund managers, Effective Date of Title IV, registration requirements, Mid-Sized Managers, Securities Commissioner, Exemption, hedge fund industry, Unregistered Managers, SEC-Registered Managers, Substantive Provision, effective date, net assets, Commission on Form ADV, Incentive-Based Compensation Arrangements, Hedge Fund Manager Registration Rul, performance fee, Income Thresholds, Grandfathering Provisions, equity owner, private adviser exemption, transitional relief, qualified purchaser, qualified client standard, Investment Adviser Registration Depository, IARD, SEC, Registration Process, SEC's Contract, IARD System, Duplicative Filing, NSMIA, Form ADV-T, regulatory assets under management, Proprietary Accounts of the Manager, Threshold of $25 Million, assets under management, Portfolios, investment adviser, Form ADV Part 1A, Instruction 5.b., threshold, registration, state securities commission, Mid-Sized Manager, SEC-registered investment advisers, Family Accounts, Proprietary Accounts, pooled investment vehicle, gross assets, hedge funds, leverage, collateral, counterparties, FSA, systemic risk, Basel Committee on Banking Supervision, Leverage Ratios, European Central Bank, Bank of America-Merrill Lynch, Columbia University, The Turner Review, Definition, proprietary information, valuation methodology, generally accepted accounting principles, GAAP, Debt-to-Equity, Instruction 5.b(4), Fair Value Methodology, International Accounting Standards, Difficult-to-Value Assets, Valuation Information, Private Fund Information, Compliance Risks, public disclosure, beneficial owners, Investor Protection Benefits, Fair Valu Hierarchy, Schedule D, Section 7.B.1, Proposed Items 14, 15, 17, 13 and 29, 11 and 12, $1 Billion, Incentive-Based, Excessive Compensation, banks, Credit Unions, broker dealers, assets, Proposed Items 5.A, 5.D and 5.F, Form ADV, Part 1A, Proposed Instruction 1.b., hedge fund managers, Depository Institutions, Taxpayer Money, National Securities Exchanges, Wealth and Income Requirements, Tier 1 Financial Holding Company, Compensation Structure, Unit-Linked Life Insurance,

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 Comments on SEC Regulatory Initiatives Under the Dodd-Frank Act09.22.10


MFA submitted initial comments to the SEC and the CFTC on regulatory initiatives in each agencys purview under the Dodd-Frank […]

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Topics: Commodity Futures Trading Commission CFTC, Securities and Exchange Commission, SEC, financial regulatory system, hedge funds, financial crisis, institutional investors, OTC derivatives market, over-the-counter derivatives market, systemic risk, operational risk, transparency, capital markets, U.S. Banking Industry, Columbia University, Investment Company Institute, Federal Financial Institutions Examination Council, leverage, market discipline, investor confidence, market stability, risk capital, proprietary strategies, international coordination, financial risk, business risk, swap dealer, swap, Counterparty, market maker, futures commission merchant, FCM, futures, Major Swap Participant, msp, non-swap dealer, AIG, initial margin, variation margin, substantial position, offsetting position, clearing, central clearing, liquidity, regulatory capital requirements, creditor, depositor, Tier 1 capital, pension plans, endowments, cleared swaps, uncleared swaps, security-based swaps, collateral, non-bank MSP, Swap Execution Facility, SEF, futures market, risk management, central counterparties, CCP, risk model, customer protection, risk committee, proprietary asset, customer asset, third party custodian, segregation, omnibus account, individual account, reporting, Designated Contract Market, market integrity, physical market, position limits, contract market, commodity trading advisor, CTA, investment adviser, Peavey Commodity Futures Fund no-action letter, commodity pool operator, Financial Stability Oversight Council, FSOC, Office of Financial Research, owned funds, residual value, managed funds, investment portfolio, roll-over, commercial paper, credit exposure, Federal Deposit Insurance Corporation, FDIC, Troubled Asset Relief Program, TARP, Federal Reserve, "too big to fail, bankruptcy law, Bondholder, private investment funds, mutual fund, client, pooled vehicle, pooled investment vehicle, Investor Protection, self-regulatory organization, SRO, investment adviser examination, Comptroller General of the United States, capital formation, Office of Compliance Inspections and Examinations, OCIE, private funds, global banks, retail clients, proprietary information, Confidential Information, Venture Capital Fund, family office, accredited investor, qualified client, knowledgeable employees, transitional relief, performance reports, market makers, Broker, fiduciary, Major Security-Based Swap Participant, MSSP, registration, margin requirement, risk profile, financial entities, Price Manipulation, executive compensation, many-to-many platform, covered financial institution, Incentive-Based Compensation Arrangements, Regulation D, disqalifying felons, Bad Actors, CUSIP number, short selling, Disclosure, price discovery, volatility, retail funds, global market, equity market, herding, Form SH, beneficial ownership, short swing profit reporting, fiduciary standard, Investor Advisory Committee, European Commission, EC, European Union, EU, European Parliament, EP, European Council of Finance Ministers, alternative investment funds, AIFs, SEC-registered advisers, Secretary Geithner, European Commissioner Michel Barnier, U.K. Chancellor of the Exchequer Alistair Darling, non-bank financial companies,

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,

MFA Comments to SEC on Custody of Funds or Securities of Clients by Investment Advisers07.28.09


MFA submitted a letter to the Securities and Exchange Commission today in response to its proposed amendments to its custody […]

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 Submits Comments to IOSCO on Consultation Report on Hedge Funds Offered to Retail Investors05.31.06


MFA Submits Comments to IOSCO’s “Regulatory Environment for Hedge Funds” survey

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Topics: Consultation Report on Hedge Funds Offered to Retail Investors hedge funds, The Regulatory Environment for Hedge Funds, hedge fund industry, alternative investment industry, fund of funds, managed futures funds, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, CFTC, Federal Reserve System, Department of the Treasury, United States Congress, MFA's Sound Practices for Hedge Fund Managers, MFA's 2005 Sound Practices, dealers, credit derivatives, investor, valuation, regulation, single-manager hedge funds, IOSCO, International Organization of Securities Commissions, IOSCO Technical Committe Standing Committee on Investment Management, SC5 2003 Report, Federal Securities Laws, hedge fund managers, Code of Ethics, pooled investment vehicle, private equity, venture capital, real estate funds, sophisticated investors, institutional investors, due diligence, absolute return strategies, FTSE-250, S&P 500, investment advisers, registered investment companies, RICs, private fund, client, Look Through, investment company, assets under management, AUM, commodity pool operator, CPO, futures, options contracts, futures exchange, commodity trading advisor, CTA, National Futures Association, NFA, reporting requirements, Regulation D, accredited investors, registered public offerings, implications of the growth of hedge funds, fraudulent behavior, Senate Banking Subcommittee on Securities, Fair Value, net asset value, NAV, pricing, illiquid investments, derivatives, hard-to-v, side pocket, conflict of interest,