MFA Comment Letters

Please contact Nick Simpson with any questions or technical difficulties. You can email your request to nsimpson@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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Comment Letter to the CFTC on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for Swap Dealers and Major Swap Participants02.28.11


MFA submitted a comment letter to the CFTC on its proposal on Confirmation, Portfolio Reconciliation, and Portfolio Compression Requirements for […]

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Topics: Commodity Futures Trading Commission CFTC, confirmation, portfolio reconciliation, portfolio compression requirements, swap dealers, major swap participants, SDs, MSPs, operational abilities, market participants, post-trade exercises, mandated timeframes, Counterparty, trade execution, SEC, Securities and Exchange Commission, valuation data, bilateral portfolio compression exercise, multilateral portfolio compression exercises, swap markets, pre-trade draft acknowledgement requirement, customized swaps, heavily negotiated swaps, time-sensitive swaps, hedging risk, limiting parties, volatility, bid spreads, offer spreads, over-the-counter derivatives, legal risks, rights, trade acknowledgment, consistent timing, confirmation periods, financial entities, pension plans, private funds, insurance companies, banks, swap portfolio trade confirmation, electronic processing, calendar day, financial entity, trade capture system, electronic matching platforms, electronic matching process, complex swap, life cycle events, timing requirements, novation, modification, partial termination, dividend payment, merger, market disruption, compliance period, clearance, exchange execution, clearing satisfying requirements, Designated Contract Market, DCM, Swap Execution Facility, SEF, derivatives clearing organization, DCO, confirmation requirement, collateral management, counterparty risk, market risk, position level discrepancies, margin disputes, position level portfolio reconciliation, best practices, bilateral portfolio reconciliation exercise, multilateral portfolio reconciliation exercise, Valuation Disputes, valuation discrepancy, nominal value, dollar threshold, broader markets, collateral steering committee of the International Swaps and Derivatives Association Inc., ISDA, market-driven solution, portfolio compression rule, operational risk, risk mitigation benefits, multilateral compression, swaps portfolio, liquidity,

Comment Letter on Proposed Rulemaking for Systemically Significant Institutions02.25.11


MFA submitted a letter to the Financial Stability Oversight Council in response to the Councils proposed rule regarding the criteria […]

Comment Letter to the SEC on Establishment of a Registration Regime for Municipal Advisors as Required by the Dodd-Frank Act.02.22.11


MFA submitted a comment letter to the SEC in response to its proposal to establish a registration regime for municipal […]

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Topics: Securities and Exchange Commission SEC, municipal advisors, duplicative registration, investment advisers, commodity trading advisors, CTAs, pooled investment vehicles, municipal financial products, municipal securities, guaranteed investment contracts, investment strategies, municipal escrow investments, pools of assets, pooled investment vehicle, municipal advisor, primary investors, private fund managers, solicitation, common control, third-party solicitor, SEC regulation, CFTC regulation, regulated persons, registered broker-dealer, pay to play rule, SEC-registered entities, registered investment advisers, registered CTAs, municipal advisory activities, municipal derivatives, commodity for future delivery, option, securities futures product, Security-Based Swap, bank deposits, investment advisory services, ancillary services, registered advisor, regular oversight, state-registered investment advisors, exempt reporting advisers, state entity, self-regulatory entity, state securities commission, mid-sized adviser, participating affiliate agreements, no-action letters, affiliate letters, SEC resources, multi-jurisdictional advisory firms, venture capital funds, private fund advisors, foreign private advisers, SEC No-Action Letter, Uniao de Banco de Brasileiros, Kleinwort Benson Investment Management Limited, Murray Johnstone Holdings Limited, ABN AMRO Bank N.V., Royal Bank of Canada, SEC oversight, transition period for registration, private adviser exemption, Form MA, dually-registered investment advisers, Form ADV,

Comment Letter to the CFTC on Business Conduct Standards for Swap Dealers and Major Swap Participants with Counterparties02.22.11


MFA submitted a comment letter to the CFTC on its proposal on Business Conduct Standards for Swap Dealers and Major […]

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.,

Comment Letter to the Department of Labor in Response to the Departments Proposed Rule to Amend the Definition of Fiduciary Under ERISA02.03.11


MFA submitted a comment letter to the Department of Labor in response to the Departments proposed rule to amend the […]

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Topics: Employee Benefits Security Administration Department of Labor, DOL, ERISA, alternative investment vehicles, hedge funds, diversification, risk management, equity markets, fixed income markets, Joseph Dear, California Public Employees' Retirement System, Senate Banking Subcommittee on Securities, Insurance and Investment, pension fund, rate of return, fee structure, performance fee, total returns, hedge fund managers, risk-adjusted returns, high water marks, government safety new, pooled investment funds, Congress, Securities and Exchange Commission, SEC, Commodity Futures and Exchange Commission, CFTC, non-plan asset funds, plan asset vehicles, general partner, DOL regulations, equity securities, plan assets, market concern, Investor Protection, private investment fund, principal underwriter, fiduciary, appraisals, pricing services, custodians, appraisers, managing member, Internal Revenue Code, pooled investment vehicles, fiduciary liability insurance. prime brokerage, daily mark, swap counterparty, fund administration agreements, asset-based fee compensation, prohibited transaction provisions, net asset value, hard-to-value, private equity holdings, real estate holdings, side-pocket investments, appraisal of property, investment advisers, valuation firm, hedge fund manager, private pension, good faith estimate, may be considered standard, significantly influence standard, ERISA fiduciaries, mutual understanding, valuation of assets, "may be considered" advice, risk appetites, tailored advice, pooled investment fund, exemption applications, transaction reversal, excise taxes, selling exception, due diligence, adverse, marketing services, impartial investment advice, purchaser, seller, bilateral agreement, default, derivative markets, short sales, options, structured products, futures, settlement accommodations, overdraft coverage, inadvertent fiduciary status, pooled vehicle, market color, prime brokers, general partners,