MFA Comment Letters

Topic: qualified purchaser

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 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,

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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