MFA Comment Letters

Topic: schedule B

Comment Letter to the SEC and CFTC on Definitions of “Swap Dealer, Security-Based Swap Dealer (together, SDs), Major Swap Participant, Major Security-Based Swap Participant (together MSPs) and Eligible Contract Participant (ECP)02.22.11


MFA submitted a comment letter to the SEC and CFTC on their joint proposed rule to further define swap dealer, […]

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Topics: Commodity Futures Trading Commission Securities Exchange Commission, CFTC, SEC, Swaps dealer, SD, Security-Based Swap Dealer, Major Swap Participant, Major Security-Based Swap Participant, msp, security-based swaps, market activity, market growth, systemic risk, United States financial markets, potential future exposure test, systemically important, MSP thresholds, Dealer, end-users, default risk, risk-mitigating tools, hedge fund managers, potential future exposure calculation, over-collateralization, current uncollateralized outward exposure test, independent amount of collateral, initial margin, mark-to-market exposure, ISDA master agreements, daily variation margin calls, valuation of collateral, future exposure discount, centrally cleared positions, central clearing, clearing member defaults, clearinghouse, variation margin, daily volatility, risk mutualization, discount factor, independent variable, tools of credit protection, reproducible test, credit default swaps, CDS, index CDS, unpaid premiums, portfolio risk, fixed downside risk, interest rate swap, LIBOR, swap rate, market-standard discount rate, CDS protection, index reference entity, volatility, jump-to-default risk, single-name CDS, risk factor multiplier, high yield credit swaps, investment-grade credit swaps, credit spreads, credit ratings, investment grade, non-investment grade, margin methodologies, bank capital standards, Chicago mercantile exchange, CME, Financial Industry Regulatory Authority Inc., FINRA, multiplier, spread bank designation, swap underlier, swaptions, options on a swap, physically settled swaptions, cash settled swaptions, option expiration date, Form PF, delta weighting, Financial Stability Oversight Council, large private fund, smaller private fund, Form PQR, MSP definitions, Proposed Form PF section 1b, question 11, question 27, proposed form PF section 2(a), question 38, proposed form PF section 3, question 47, proposed form PF section 4, question 68, proposed Form PQR, schedule B, question 5, substantial counterparty exposure, MSP test, substantial position, undiversified market participant, counterparty exposure, systemically important financial institution, commercial hedging, index derivatives, commercial loans, mitigating commercial risk, threshold levels, dealers, uncollateralized exposure, potential systemic risk impact, inflation, upward adjustment, U.S. banking system, highly leveraged, liabilities to equity, asset mix, liquidity, liquidity rights, capital markets, secured debt, unsecured debt, short-term leverage, overnight borrowing, short-term financing, highly liquid assets, US Treasuries, longer-term leverage, term borrowings, risk factor multipliers, high-grade corporate securities, FSOC, hedge funds, eligible contract participant, ECP, non-ECP, financial counterparty, traditional commodity pool, Retail Forex Pool, SD obligations, retail cash, currency based institutions, limited purpose designations, minimum duration of status, quarters, deregistration period, reevaluation period, abnormal price movement, applicable MSP thresholds, master-feeder fund, feeder fund, trading entity, MSP determination, Senator Hagan, Senator Lincoln, creditworthiness, know your counterparty requirements, daily mark requirements, trade verification, acknowledgment requirements, fund domicile, manager domicile, reference entity domicile, market location, underlying instrument, counterparty domicile, US entities, non-US entities, non-US domiciled fund, non-US securities, non-U.S. market, offshore fund, non-U.S. regulators.,

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,
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