MFA Comment Letters

Topic: threshold

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

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Topics: private funds commodity pool operators, commodity trading advisors, Form PF, systemic risk, Financial Stability Oversight Council, market participants, managed futures, absolute return strategies, SEC, CFTC, Dodd-Frank Act, Council and Office of Financial Research, OFR, global regulators, overcounting, undercounting, threshold for enhanced performance, assets under management, reporting period, confidentiality protections, inadvertent disclosure, non-bank financial companies, lending institutions, interconnectedness, liquidity risk, maturity mismatch, regulatory scrutiny, systemically significant, Federal Reserve System, the Fed, Form CPO, Form PQR, Form CTA-PR, targeted requests, tiered reporting system, threshold, trading and investment strategies, borrowing arrangements, collateral practices, operational capabilities, illiquid assets, investment advisers, bespoke contracts, private equity, privately issued convertible bonds, equity derivatives, distressed debt, unaffiliated third party sources, generally accepted accounting principles, GAAP, Level 2 inputs, Level 3 inputs, Financial Accounting Standards Board, audited financial statements, UK Financial Services Authority, FSA, Form 13F, public companies, Form 10-K, Form 10-Q, portfolio management, CUSIP number, semi-annual reporting, counterparty exposures, market noise, short-term market fluctuations, margin requirements, hedge fund defaults, large private fund manager, qualifying fund, hedge fund assets under management, Form ADV, proposed reporting thresholds, interpretive guidance, private fund managers, recordkeeping requirements, section 404, confidentiality of information, proprietary information, Investment Adviser Registration Depository, Schedule 13G, individual certification, valuation methodology, proprietary methodology, alternative methodology, de minimis, master-feeder, parallel funds, equity prices, interest rates, currency rates, Form PF question 36, form PF questions 28 and 35, funds of funds, direct investments, aggregate gross asset value, collateral, operational efficiency, ten-year option, five-year option, master agreement, regulatory assets under management, net assets under management, leverage, parallel managed accounts, net asset value, gross asset value, creditor, net borrowings, aggregate borrowings, beneficial owners, record owners, fixed advisory fees, investment expenses, performance fees, inception class, statistical arbitrage-equity, other quantitative strategies, strategy exposure, risk capital allocation, NAV, futures commission merchants, FCMs, direct clearing members, DCMs, prime brokers, clause (iii), loan commitments, offsetting exposure, tri-party collateral accounts, market value, asset-backed securities, debt securities, swap contracts, futures contracts, foreign currency contracts, notional value of derivatives, notional amount, long positions, short positions, LMV, SMV, maturity brackets, short-term interest rate, DV01, CR01, duration, non-rated issues, short term high quality corporate debt, foreign exchange derivatives, turnover rate, GMV, Bloomberg, risk methodology, repos, sensitivity analyses, liquidity management, balance sheet value, delta adjusted, variation margin, equity exposure, rehypothecated initial margin, CCPs, central clearing counterparties, Value at Risk, VaR, CDS, CDX, default rates, corporate bonds, short borrowing, synthetic borrowing, uncommitted lines of credit, side pocket arrangement,

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,
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