MFA Comment Letters

Topic: regulations

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 Letter to IRS Regarding Compliance Issues for Private Investment Funds Filing a Foreign Bank and Financial Accounts Report05.13.09


MFA submitted a letter as a follow up to its meeting on April 7 with officials from the IRS to […]

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Topics: FBAR Requirements private investment funds, Internal Revenue Service, IRS, Foreign Bank and Financial Accounts Reports, hedge funds, prior submissions, Patton Boggs LLP, Office of Chief Counsel, regulations, covered financial accounts, U.S. tax-exempt investors, master-feeder structures, domestic feeder fund, group filings, Form TD 90-22.1, cost-efficient, Fund Managers, compliance, adverse guidance, Glen Kirkland, IRS Reports Clearance Officer, OMB No. 1545-2038, limited liability companies, signature authority, taxpayer identification number, banks, publicly-traded corporations, tax-exempt organization, SRZ, Partnerships, bonds, notes, stock certificates, equity interest, John G. Gaine, Don Carbaugh, Financial Crimes Enforcement Network, FinCEN, United States Department of the Treasury, William Langford, federal tax return, Form TDF 90-22.1, Detroit Computing Center of the Internal Revenue Service, private equity, domestic limited partnerships, domestic limited liability companies, flow through, brokerate accounts, foreign currencies, foreign securities, interpretive guidance, general definitions, derivatives, savings, demand, checking, deposit, mutual fund, illiquid, lock-up periods, tax forms, Form 990, Form 990-PF, Form 5500, Form 1040, schedule B, Question 7a, Form 1065, Question 9, Form 1120, Schedule N, Questioon 6a, AML program rule, pooled interest, control the disposition, Form TD F 90-22, Betty Santangelo, Nancy Rose, Carl E. Kennedy, Don Moorehead, commodity trading advisors, commodity pool operators, legislators, President's Working Group on Financial Markets, PWG, Side-by-Side Structure, board directors, filing exception, FBAR, Schulte Roth & Zabel LLP, federal register,

MFA Letter to SEC on August 2007 New York Regional Office Examination Request Letter12.20.07


MFA submits comments to the SEC on the August 2007 New York Regional Office Examination Request Letter.

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Topics: August 2007 New York Regional Office Examination Request Letter Office of Compliance Inspections and Examinations (OCIE), New York Regional Office, Chief Compliance Officers, registered investment advisers, periodic examinations, Pilot program, compliance, Federal Securities Laws, regulations, Investor Protection, hedge fund advisers, advisers, legal risk, examination process, pre-examination letters operational resources, registrants, risks, risk-based approach, Lori A. Richards, Director of SEC's Office of Compliance and Inspections and Examinations, CCOutreach National Seminar, National society of compliance Professionals National Membership Meeting, surveillance, complianceAlert, Ninth Annual IA Compliance Best Pracitces SUmmit 2007, CCO Seminars or Roundtables, chief compliance officer seminars and roundtables, focus group, reqests II(D)(1), public company affiliation, relative, corporate insiders, request V(G)(1), Request II(J)(1), bankruptcy workout, Request II(G)(1), II(H)(1), IIIJ(1), III(M)(1), III(M)(3), III(N)(1), III(N)(2), conflicts of interest, sales coverage, adviser, broker-dealer, operations, technology, I(G), II(A)(2), II(A)(3), and VI(B)(1), Microsoft Excel spreadsheets, data mining, medium, standardized presentations, V(E)(2), V(E)(3), VIII(G), IX(F)(2)m X(I)(2), written complaint, shareholder communications, public pension funds, candidates, Request II(A)(1), attorney-client privilege, potential transactions, arrangements, Request II(B)(3), portfolio allocation, consistency, Request II(D)(3)(e), Request IV(A)(1)m block trades, Request V(A)(4), Code of Ethics, public, Form ADV Part II, Securities and Exchange Commission, SEC,
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