MFA Comment Letters

Please contact Scott McDonald with any questions or technical difficulties. You can email your request to smcdonald@managedfunds.org or call 202-730-2600. MFA is continuously updating the database, so check back often when searching for comment letters.

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MFA Files Amicus in Lehman Litigation to Support Judicial Asset Sale Process09.28.12


MFA filed an amicus brief in the Barclays Capital and LBI SIPA Trustee litigation before the Second Circuit Court of […]

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Topics: amicus brief U.S. Court of Appeals for the Second Circuit, Lehman Brothers Holding Inc., Barclays Capital, James W. Giddens, Securities Investor Protection Corporation Trustee, amicus curiae, capital markets, no-cash deal, bankruptcy, Bankruptcy Code, Acton v. Fullmer (In re Fullmer), Adelphia Recovery Trust v. HSBC Bank USA (in re Adelphia Recovery Trust), Bass v. Parsons (In re Parsons), Big Shanty Land Corp. v. Comer Props. Inc., Folger Adam Security Inc. v. Dematteis/MacGregor, In re Cavalieri, In re Cedar Tide Corp, In re F.A. Potts & Co., In re Fehl, In re Gulf Coast Oil Corp., In re Integrated Res. Inc., In re Sapolin Paints Inc., In re Savage Indus. Inc., In re Silver Bros. Co., In re Smith, In re Weisser Eyecare Inc., M.R.R. Traders Inc. v. Cave Atlantique, Matter of Pease, Med. Malpractice Ins. Ass'n v. Hirsch (In re Lavigne), Meinwald v. Meinwald, Morgan Olson LLC v. Federico et al. (In re Grumman Olson Indus. Inc.), United States v. Sforza, Walker v. Lee (in re Rounds), Winston Inn & Rest. Corp. v. DeMichiel (In re Winston Inn & Rest. Corp.), Rob Copeland, Kelly DePonte, Financier Worldwide, Adam Levitin, Richard Mikels, Ella Shenhav, SIFMA, Illinois, Managed Funds Association, MFA, public policy, alternative investment industry, best practices, pensions, endowments, institutional investors, risk management, Australia, Europe, Asia, assets under management, AUM, bankruptcy court, transparency, contract, stakeholders, Clarification Letter, Lehman Margin Cash, purchaser, LBHI, Lori Fife, Harvey Miller, borrowers, lenders, secondary offerings, liquidity, interest rates, debtor, United States Bankruptcy Court for the Southern District of New York, free and clear, banks, New York Adelphia, litigant,

MFA Submits Comment Letter in Response to Basel-IOSCO’s Consultative Document on Margin Requirements for Non-Cleared Derivatives09.28.12


MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision […]

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Topics: Basel Committee on Banking Supervision International Organization of Securities Commissions, IOSCO, margin, margin requirements, non-centrally cleared derivatives transactions, Working Group on Margining Requirements, derivatives, derivatives markets, margining, clearing, market participants, central clearing, risk management, initial margin, variation margin, best practices, liquidity, mandatory clearing, bilateral exchange, buy-side firms, segregated account, custodian accounts, hedge, hedge funds, netting, eligible collateral, portfolio margining, over-collateralization, mutually offsetting transactions, margin threshold, harmonization, uniformity, non-compliance, regulatory arbitrage, market advantage, phase-in period, implementation timeline, non-cleared derivatives, regulatory authorities, foreign exchange, swaps, forwards, risk profile, market infrastructures, liquidity characteristics, currency, Denominated in G7 Currencies, G7, cleared derivatives, systemic risk, systemic importance, systemically important, systemically important non-financial firm, liquidity costs, unlevel playing field, transparency, SIFI, systemic risk level, credit, unsecured credit extension, minimum transfer amount, MTA, prudentially regulated financial counterparties, two-way margining, standard practice, credit risk, clearing house, bilateral exchange of variation margin, market liquidity, credit default swap, CDS, novation, remaining party, party stepping out, party stepping in, novating parties, market value, Regulators, novation arrangements, liquidity mechanism, asset classes, liquidation, Dodd-Frank Act, European Union, EU, United States, ISDA, International Swaps and Derivatives Association, replacement transaction, market practices, cross-product master netting agreements, risk offsets, financial instruments, U.S. Treasury futures, Eurodollar futures, non-cleared interest rate swaps, repurchase agreements, correlated financial instruments, quantitative impact study, Portfolios, central counterparty, CCP, hedged portfolios, prudential regulators, risk characteristics, risk/reward profile, diversification, concentration limits, haircuts, segregation, third-party segregation, re-hypothecation, cost mitigation, Commodity Futures Trading Commission, CFTC, swap dealers, major swap participants, equities, delta, interest rates, CDS spreads, notional value, commodities,

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 Submits Comments on Hong Kong Consultation on Electronic Trading09.23.12


On September 23, MFA submitted comments to the Hong Kong Securities and Futures Commission on its consultation paper on the […]

MFA Submits Comments to USTR on Mexican Bankruptcy Law for Trade Negotiations09.04.12


MFA submitted comments to the U.S. Trade Representative (“USTR”) raising concerns with the Mexican Business Reorganization Act as demonstrated by […]