MFA Comment Letters

Topic: private equity funds

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

Letter to ERISA Advisory Council on Hedge Funds’ Benefit to Pensions and Beneficiaries11.01.11


MFA submitted a written statement to the ERISA Advisory Council in connection with an Advisory Council meeting on November 8 […]

Comment Letter Responding to FSB’s Background Note, ‘Shadow Banking: Scoping the Issues’05.16.11


MFA submitted a comment letter in response to the FSBs Background Note on Shadow Banking. In our letter, we discussed […]

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Topics: Financial Stability Board Shadow Banking: Scoping the Issues, shadow banking system, banks, broker dealers, Background Note, hedge fund industry, concentration of assets, low leverage, borrowing arrangements, derivatives contracts, stable capital, regulation, credit intermediation chain, Distribution/Wholesale Funding, non-bank institutional investors, long-only mutual funds, insurance companies, Pension Funds, private equity funds, large corporate investors, systemic risk concerns, maturity transformation, liquidity transformation, individual adviser, hedge fund adviser, asset concentration, asset management structures, interconnectedness of hedge funds, systemic impact of hedge funds, The UK Financial Services Authority, FSA, legal separation of different funds, bank holding companies, nonbank financial institutions, secured borrowings, manage liquidity risk, investors, bank/broker counterparts, secured basis, short term liability, repo liabilities, ABCP conduits, mutual funds, collateral, margining process, haircuts, initial margin, mark-to market margining, repo sellers, repo collateral, highly leveraged financial institutions, hedge fund borrowings, Long Term Capital Management, LTCM, U.S. President's Working Group on Financial Markets, counterparty risk management, Counterparty Risk Management Policy Group, hedge fund leverage, regulatory arbitrage, regulatory arbitrage concerns, off-balance sheet vehicles, direct regulation of entities, U.S. Securities and Exchange Commission, macro-prudential approach,

MFA Comments to IRS on Application of FBAR to Private Investment Funds and Related Issues10.05.09


MFA submitted a letter to the IRS in response to IRS Notice 2009-62, which requests comments and recommendations concerning the […]

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Topics: Internal Revenue Service IRS, private investment funds, Reports of Foreign Bank and Financial Accounts, FBAR, hedge funds, private equity funds, Department of the Treasury, Financial Crimes Enforcement Network, FinCEN, filing obligation, foreign financial account, banks, publicly-held companies, non-public companies, chief financial officer, U.S.-based manager, Internal Revenue Code, FIRPTA, effectively connected income, financial institutions, foreign financial agencies, private sector, signatory authority, covered foreign financial account, commingled fund, Corporation, partnership, mutual funds, non-U.S. hedge fund, non-U.S. private equity fund, open-ended mutual funds, redemption terms, redemption policy, liquidity, financial accounts, New York State Bar Association, bank account, securities account, Lock-up, Tax Section of the New York State Bar Association, Neal S. Wolin, Michael Mundaca, Douglas H. Shulman, James H. Freis, third party transfers, broker-dealer, Passive Foreign Investment Companies, PFICs, PFIC shareholder filing requirements, Form 8621, Form 926, foreign corporations, Form 5471, Form 8865, U.S. tax return, Form 1065, non-U.S. hedge funds, money laundering, other authority, financial interest, master fund, hedge fund manager, Deferred Fees, hedge fund management companies, foreign prime brokerage, officer, partner, Investment Fund Managers, portfolio manager, investment officer, investment fund management company, Other Account Authority, Workbook on the Report of Foreign Bank and Financial Accounts, shareholders, investors, non-U.S. investors, primary owner, United States Person, domestic partnership, domestic corporation, domestic estate or trust, persons in and doing business in the United States, domestic taxpayers, safe harbor, U.S.-based managers,

MFA Comment Letter to Canadian Securities Administrators on Registration Reform06.29.07


MFA submits comments and attachment to the Canadian Securities Administrators on Canadian registration reform.

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Topics: British Columbia Securities Commission Alberta Securities Commission, Saskatchewan Financial Services Commission, Manitoba Securities Commission, Ontario Securities Commission, Autorite des Marches Financiers, New Brunswick Securities Commission, Register of Securities Prince Edward Island, Nova Scotia Securities Commission, Superintendent of Securities Newfoundland and Labrador, Register of Securities Northwest Territories, Register of Securities Yukon Territory, Register of Securities Nunavut, Proposed National Instrument 31-103, registration requirements, global alternative investment industry, hedge funds, fund of funds, managed futures funds, policymakers, absolute return strategies, hedge fund industry, regulatory authorities, educational outreach, alternative investment history, Commodity Futures Trading Commission, CFTC, Federal Reserve Board, Department of the Treasury, Canadian Securities Administrators', CSA, global financial marketplace, President's Working Group on Financial Markets, PWG, private pools of capital, capital markets, financial markets, liquidity, price efficiency, risk distribution, alternative investment opportunities, capital, funds, Canada, (NI31-103), alternative investment vehicles, regulation, privately offered fund, professional investment management for hedge fund managers, defined term, U.S. federal securities laws, investment company, venture capital, private equity, leveraged buyout, oil and gas, real estate funds, hedging, distressed, financing, large activist posistions, risk-adjusted performance, private equity funds, assets under management, AUM, Non-Canadian Hedge Fund Securities, capital raising, retirement plans, pension plans, exposure, international capital markets, National instrument 45-106, Prospects and Registration Exemptions, Labrador, non-resident dealers, limited market dealers, dealer registration requirements, Non-Ontario Regime, securities, Regulatory Authority, offering memorandum, offering document, Ontario Regime, prospectus exemption, disclosure obligations, dealer registration exemption, market intermediaries, flow-through analysis, adviser registration, commodity futures, non-resident exemptions, Commodity futures act, Administrative Costs, Fraud, international portfolio manager, international investment fund manager, advisers, fund units, Ontario registered dealer, registered broker-dealer, broker-dealer, exempt market trades, accredited investors, sophisticated investors, fund-of-funds, financial institutions, hedge fund consultant, private placement, White Paper, financial eligibility, standards, pooled investment products, investment sophistication, natural persons, net worth threshold, annual income threshold, private investment vehicles, accredited natural person, income tests for inflation, grandfather provision, dealer registrayion exemption, offshore investment vehicles, United Kingdom, European Union, EU, well-developed capital markets, regulatory regimes,
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