MFA Comment Letters

Topic: pooled investment vehicles

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 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 […]

MFA Files Joint Comment Letter to California Department of Corporations on Proposed Rule Requiring Hedge Fund Managers to Register with the State11.21.07


MFA and the Coalition of Private Investment Companies submit a joint comment letter to the California Department of Corporations on […]

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Topics: Department of Corporations California Corporate Securities Law, Coalition of Private Investment Companies, CPIC, Commisioner of the California Department of Corporations, investment advisers, California, global alternative investment industry, hedge funds, managed future funds, proposal, Congress, jobs, office rents, support services, tax revenues, Investor Protection, de minimis standard, state registration, venture capital, investment adviser, national markets, Exemption, public, registered investment companies, private offerings, initial statement of reasons, jurisdiction, implications of the growth of hedge funds, 2003 staff report, industry trends, oversight, Fraud, fund advisers, Pension Funds, privately-offered pooled investment vehicles, due diligence, accredited investors, qualified purchasers, Board of Governors of the Federal Reserve System (FED), professional asset managers, fiduciary standards, New York, London, San Francisco, Exempt Advisers, financial products, risk, start-up companies, liquidation restrictions, locked up, Redemptions, capital calls, liscensing exemption, pooled investment vehicles, accredited investor standard, Private Offering, Form D, Data, electronic filing, requirement, Investor's Committee of the Advisory Group, financial market, Industry Standards, Agreement Among PWG and U.S. Agency Principals on Principles and Guidelines Regarding Private Pools of Capital, registrant, training personal, The Bureau of National Affairs, Sound Practices for Hedge Fund Managers, spillover effect, brokerage firms, James Chanos, chief investment officer, CalPERS, California Public Employees' Retirement System, Department of the Treasury, Commodity Futures Trading Commission, CFTC, President's Working Group on Financial Markets, PWG, Securities and Exchange Commission, SEC, assets under management, AUM, fund of funds,

MFA Comments to SEC Regarding Proposals to Revise Limited Offering Exemptions in Regulation D10.19.07


MFA submits a comment letter to the SEC regarding their proposals to revise the limited offering exemptions in Regulation D.

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Topics: Limited Coffering Exemptions global alternative investment industry, hedge funds, managed futures funds, policymaker, flexibility, issuers, Accerdited Investor, accredited natural person, offers, securities, limited announcement, offering, pooled investment vehicles, transactions, Public Offerings, General Solicitation, General Advertising, investor, accredited investor, higher dollar-amount thresholds, qualification, capital, Private Pooled Investment Vehicle Release, financial sophistication standards, federal regulations, natural persons, privated pools of captial, inflation, financial eligibility standard, joint income thresholds, Office of Economic Analysis, capital formation, compliance, implications of the growth of hedge funds, Offerings, private placement offerings, qualifies purchasers, Qualified Purchaser Definition, Qualified Client Definition, marital assets, Joint Investments, qualified client, qualified purchaser, Subscription Agreement, pooled investment fund, subscription agent, sophisticated investors, United States, Future Inflation Adjustment, dollar-amount threshols, private placement, knowledgeable employees, Trust Grantors, Trustees, beneficiaries, Sophisticated Investor Standards, risk, transaction costs, economic efficiency, Investor Protection, Investor relations professionals, research analysts, attorneys, traders, brokers, traders of a fund affiliate, senior financial, operational, accounting officers, risk/return, deferred compensation, net worth, investments tests, Issuer, fund principals, pooled investment funds, retention tool, start up company, sotck, equity owners, primary beneficiary, Grandfathered, inflation adjustments, dollar-amount thresholds, grandfather provision, due diligence, committed capital, Interation Safe Harbor, transparency, Manner of Offering, sale limitations, Disqualification Provisions, predecessor, affiliated issuer, director, executive officer, general partner, managing member, 20% beneficial owner, promoter, cease and desist, Fraud, Form D, blue sky filing, bad actor disqualification provisions, recdivism, Division of Enforcement, U.S. Congress, Securities and Exchange Commission, SEC, threshold,

MFA Submits Comments to SEC on Proposals for Accredited Natural Person and Antifraud Rules03.09.07


MFA submits comment letter and attachment to the SEC on Proposals for Accredited Natural Person and Antifraud Rules.

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Topics: Securities and Exchange Commission SEC, private investment vehicles, Accredited Natural Person Proposal, Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles, Investor Protection, alternative investment industry, capital markets, hedge funds, managed futures funds, President's Working Group on Financial Markets, PWG, private pools, liquidity, price efficiency, risk distribution, Regulatory Structure, direct investment, Christopher Cox, Robert Steel, venture capital, private equity, industry innovation, Department of the Treasury, cash room, Randal Quarles, Senate Committee on Banking Housing and Urban Affairs, risk-adjusted performance, accredited investor standard, financial eligibility standards, accredited investor, pooled investment vehicles, net worth threshold, financial eligibility standard, Pui-Wing Tam, Jonathan Shieber, Stephen Heuser, qualified client, qualified purchaser, qualified institutional buyer, qualified eligible person, eligible contract participant, joint property, net worth, Office of Economic Analysis, 3(c)(1) funds, illiquid investments, real estate, Lock-up, U.S. economy, Stuatory Authority, 100 beneficial owners, beneficial owners, 3(c)(7) funds, deferred compensation, fund employees, American Bar Association, research analysts, legal counsel, traders, broker dealers, attorneys, brokers, compliance, operational, accounting officers, grandfathering provision, competition, start-up funds, antifraud proposal, Goldstein decision, scienter, transparency, dialogue, Request for Proposal, private placement memorandum, Limited Partnership Agreement, Subscription Agreement, due diligence, management, incentive compensation, conflicts of interest, side letters, withdrawal, transfer procedures, tax issues, ERISA Issues, Thomas Lemke,
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