MFA Comment Letters

Topic: private fund

MFA Submits Comments in Response to SEC Proposed Amendments to Regulation D, Form D and Rule 15609.23.13


MFA submitted a letter to the Securities and Exchange Commission in response to proposed amendments to Regulation D, Form D […]

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Topics: Securities and Exchange Commission SEC, Regulation D, Form D, market practices, JOBS Act, General Solicitation, private placements, capital formation, Investor Protection, transparency, private fund, private capital markets, hedge funds, issuers, due diligence, John Thune, registered investment companies, RICs, private fund managers, examination process, Office of Compliance Inspections and Examinations, OCIE, hedge fund industry, assets under management, AUM, Form ADV, state securities regulators, Form PF, proprietary information, Rulemaking, adviser registration, Norm Champ, Division of Investment Management, PLI Hedge Fund Management Conference, Advance Form D, cost-benefit analysis, compliance costs, registered investment adviser, hedge fund managers, compliance, public markets, Fund Sponsors, United States Congress, capital markets, Form 13F, Schedule 13D, censure, cease and desist, Verification Methods, accredited investor, general solicitation materials, legends, disclosure requirements, anti-fraud rules, performance, sophisticated investors, high net worth requirements, institutional investor, private fund offerings, retail investors, private placement memorandum, Ban on General Solicitation and Advertising, accredited investors, efficiency, competition, pitch book, marketing materials, beneficial owners, equity, natural persons, eligible purchasers, general partner, Federal Securities Laws, deemed compliant, Pacific Mutual Life Insurance Company, Variable Life, Franklin Group of Funds, investment company, statement of policy, mutual fund, interpretive guidance, commodities, derivatives, liquidity, qualified purchasers, qualified clients, Global Investment Performance Standards, investor qualification standards, knowledgeable employees, harmonization, Elizabeth Murphy, Commodity Futures Trading Commission, CFTC, pool participants, Ray Garrett, Colorado Bar Association,

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 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 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,
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