MFA Comment Letters

Topic: shareholders

MFA and AIMA Submit Joint Letter on CPSS-IOSCO Consultative Report on Financial Market Infrastructure Recovery10.11.13


MFA and AIMA submitted a joint letter to the Committee of Payment and Settlement Systems (CPSS) and the International Organisation […]

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Topics: AIMA Alternative Investment Management Association, IOSCO, International Organization of Securities Commissions, Bank for International Settlements, Bank for International Settlements Committee on Payments, consultation paper, market infrastructures, central counterparty, CCP, clearing, exchange-traded, exchange-traded derivatives, over-the-counter derivatives, OTC derivatives, prudential regulators, mandatory clearing, collateral, clearing member, systemically important financial market infrastructure, transparency, regulatory framework, risk management, EMIR, default, Unwind, ex ante measures, orderly liquidation, haircuts, G20, variation margin, financial system, market participants, risk committees, default management committees, CFTC, Commodity Futures Trading Commission, ESMA, European Securities and Markets Authority, European Union, trading venues, liquidity, shareholders, margin, title transfer collateral arrangements, security arragements, competition, sell-side firms, systemic risk, bail-in, default waterfall, margin haircut, initial margin, bankruptcy, Dodd-Frank Act, Security-Based Swap Dealer, majory security-based swap participant, capital requirements, broker-dealer, hedge, buy-side firms, physical commodity, uncleared derivative, portfolio, mark-to-market, contagion, stress-testing methodologies, financial stability, trading volume, conflict of interest, security-based swap execution facility, security-based swap clearing agencies,

MFA and AIMA Submit Letter on Canadian Early Warning Reporting System07.12.13


MFA and AIMA submitted a letter to Canadian regulators in response to proposed amendments to Canada’s Early Warning System and […]

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Topics: Canada AIMA, MFA, Alternative Investment Management Association, Canadian Early Warning Reporting System, EWR, British Columbia Securities Commission, Alberta Securities Commission, Financial and Consumer Affairs Authority of Saskatchewan, Manitoba Securities Commission, Ontario Securities Commission, Autorite des Marches Financiers, New Brunswick Securities Commission, Superintendent of Securities Prince Edward Island, Nova Scotia Securities Commission, Securities Commission of Newfoundland and Labrador, Superintendent of Securities Yukon Territory, Superintendent of Securities Northwest Territories, Superintendent of Securities Nunavut, United Kingdom, transparency, securities law, Andrew Vollmer, Paul Wolfson, Alternative Monthly Reporting, shareholders, total return swaps, contracts for difference, derivatives, OTC derivatives, eligible institutional investor, institutional investors, board of directors, regulatory regime, capital markets, Ronald Gilson, Jeffrey Gordon, Brian Cheffins, Nickolay Gantchev, Chotibhak Jotikasthira, activist hedge fund, Hedge Funds Review, Canadian Coalition for Good Governance, National Bureau of Economic Research, corporate governance, remuneration, return on assets, performance, Kimber Report, investor reporting, reporting, non-objecting beneficial owners, beneficial owners, TSX, TSX Venture Exchange, System for Electronic Document Analysis and Retrieval, SEDAR, System for Insider Data on Insiders, SEDI, Yahoo!Finance, Stockhouse, Seeking Alpha, Reuters, StockCharts, Google Finance, Morningstar, Australia, Securities and Exchange Commission, SEC, disclosure and transparency rules, voting shares, equity securities, Financial Conduct Authority, FCA, London Stock Exchange, Issuer, Counterparty, relevant interests, Australian Securities and Investments Commission, ASIC, qualified investors, banks, broker-dealer, investment company, Bank of Canada, hedge funds, New York Stock Exchange, Australian Stock Exchange, liquidity, TMX Group Limited, Canada Pension Plan Investment Board, Ontario Teachers' Pension Plan, OMERS Administration Corporation, British Columbia Investment Management Corporation, The Caisse de depot et placement du Quebec, Alberta Investment Management Corporation, Ward Phillips & Vineberg LLP, confidentiality, cost-benefit analysis, disclosures, hedging, TELUS Corporation,

MFA Submits Comments on AIFMD Remuneration09.27.12


MFA submitted comments to the European Securities and Markets Authority (ESMA) on its consultation on guidelines on sound remuneration policies […]

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Topics: ESMA European Securities and Markets Authority, remuneration, consultation paper, remuneration policies, AIFMD, European Union, EU, Policy Makers, proportionality principle, AIFM, excessive risk-taking, Identified Staff, limited liability partnership, LLP, management committees, junior partner, RemCo, deferral of remuneration and pension, European Commission, Council of the European Union, European Parliament, hedge fund managers, financial institutions, deposit-taking entity, government insurance, private placement, institutional investor, sophisticated investors, bank, Insurance, alignment of interests, owner-managed AIFM, shareholders, public shareholders, third country, Regulators, carried interest, fees, service providers, commissions, delegate, performance fee, Senior Management, investors, other risk taker, risk profile, Balance Sheet, own account dealer, operational risk, United Kingdom, affiliated group, governing body, Limited Liability Company, LLC, risk management, compliance, audit, compliance staff, counsel, chief compliance officer, control functions, parent company, credit institutions, capital requirements, MiFID, MiFID firms, distributions, minimum capital requirements, management bodies, non-executive directors, hedge funds, assets under management, AUM, Member State, Member State competent authorities, control function, pension, variable remuneration, risk alignment, material risk, UCITS, performance measures, deferred remuneration, non-deferred remuneration, Claw-Back, fee structure, redemption rights, tax, Tax Implications, bonuses, underperformance, alternative instruments, retention policy, financial stability, non-EU AIFM, marketing, EU Passport, private placement regime, Disclosure, Annual Report, Confidential Information, stakeholders,

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its “Proposed Interpretive Guidance […]

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Topics: CFTC Commodity Futures Trading Commission, interpretive guidance, swaps, Alternative Investment Management Association, AIMA, financial crisis, over-the-counter derivatives, OTC derivatives, OTC derivatives market, hedge fund industry, fund of funds, hedge fund managers, prime brokers, hedge fund administrator, market participants, non-U.S. market participants, regulatory requirements, commodity pool, pooled accounts, collective investment vehicles, non-U.S. investment fund, Securities and Exchange Commission, SEC, international harmonization of regulations, regulatory framework, duplicative regulation, transaction cost, compliance costs, U.S. person, non-U.S. persons, derivatives, derivatives markets, Corporation, partnership, limited liability companies, joint-stock company, fund, pension plans, estate, Trust, income tax, Jill Sommers, Scott O'Malia, cost-benefit analysis, market impact, third country, European Securities and Markets Authority, ESMA, direct or indirect ownership, Look Through, shareholders, listed entity, foreign banks, banks, dealers, commodity pool operator, CPO, Form CPO-PQR, financial stability, financial system, chief compliance officer, risk management, swap data recordkeeping, swap data reporting, commodity swaps, clearing, swaps processing, margining, segregation, uncleared swaps, execution, portfolio reconciliation, real-time public reporting, trade confirmations, Business Conduct Standards, qualified eligible person, accredited investors, general partnerships, registration, CPO registration requirements, counterparties, swap dealer, major swap participants, MSPs, swap data repository, sell-side firms, buy-side firms, entity-level requirement, reporting party, comment letter, transaction-level requirements, majority ownership, G20, G20 commitments, substituted compliance, transparency, Policy Makers, European Parliament, Council of the European Union, Hong Kong, Hong Kong Monetary Authority, Securities and Futures Commission, Monetary Authority of Singapore, Singapore, International Organization of Securities Commissions, IOSCO, Department of the Treasury, natural person, foreign entity, Dealer, fiduciary, International Monetary Fund, International Bank for Reconstruction and Development, Inter-American Development Bank, Asian Development Bank, African Development Bank, United Nations,

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,