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, SIFMA and GFXD Submit Joint Letter to the CFTC with Proposed Safe Harbor for the ECP Definition01.19.12


On January 19, MFA, SIFMA, and GFXD submitted a joint letter to the CFTC with a proposed safe harbor from […]

MFA Responds to ECON’s MiFID Questionnaire01.13.12


MFA submitted responses to MEP Markus Ferbers Questionnaire on MiFID/MiFAR 2, which asks for further information on certain aspects of […]

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Topics: Economic and Monetary Affairs Committee ECON, European Parliament, Questionnaire on MiFID/MiFIR 2 by Markus Ferber MEP, Markus Ferber, Markets in Financial Instruments Directive, eligible counterparties, custody, safekeeping, MiFID passport, professional clients, retail clients, equivalence, reciprocal access, regulatory capital, corporate governance rules, Securities and Exchange Commission, SEC, European Commission, management bodies, trading venues, corporate governance, broker crossing network, derivatives trading venues, derivatives, voice brokerage systems, alternative investment managers, alternative investment funds, broker dealers, relevant counterparties, clearing obligation, EMIR, European Market Infrastructure Regulation, central limit order book, CLOB, request for quote system, RFQ, algorithmic trading, high frequency trading, market-making activities, correlating instruments, mutual funds, arbitrage trading, high frequency/low latency, liquidity, flash crash, limit up-limit down measure, counterbalancing benefits, regulatory investigation, direct electronic access, DEA, co-location services, circuit breakers, abnormal trading conditions, confidentiality requirements, organized venues, public consultation, third country trading venues, EEA venues, reciprocal recognition, third country firms, straight-through processing, real-time registration, listed futures, listed equity derivatives, energy swaps, bilateral credit agreement, bilateral execution documentation, CCP, risk caps, SME, MTF SME, non-discriminatory access to market infrastructure, pre-trade market data, position limits, alternative arrangements, commodity derivatives, position management powers, hedging transactions, conflicts of interest, structured UCITS, non-structured UCITS, financial activity, shares, depositary receipts, exchange traded funds, ETF, broker liquidity, transparency, trading obligation, confidentiality safeguards, dark pools, approved publication arragement, APA, approved reporting mechanism, ARM, consolidated tape provider, CTP, European Supervisory Authorities, ESA, non-discriminatory access, real-time clearing, UCITS IV, packaged retail investment product, PRIP, organized trading facility, OTF, sanction,

Comment Letter to ESMA on Short Selling and Credit Default Swap Regulation01.10.12


MFA submitted a comment letter on January 10 to the European Securities and Markets Authority (ESMA) regarding the implementation of […]

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

Petition to SEC for Rulemaking on Rule 502 of Regulation D, Ban General Solicitation01.06.12


MFA submitted a comment letter to the SEC requesting that the Commission amend Rule 502(c) of Regulation D to eliminate […]

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Topics: Petition for Rulemaking Securities and Exchange Commission, SEC, Offers or Sales Securities, Private Funds Managers, Economic Growth, Competitiveness, Job Creation, Independent Regulatory Agencies, Investor Protections, Offerings or Sales, private funds, Administrative Costs, sophisticated investors, House of Representatives, United States Congress, Ban on General Solicitation and Advertising, Senate, Public Offering, investment company, Interpretive Framework, Broadcast Over Television, Radio, Fund Managers, Issuer, Selling Agent, Pre-Existing Substantive Relationship, Continuous Offerings, Limited Partnerships, Broker, accredited investors, Pre-Existing Relationship Doctrine, Qualified Potential Investors, Industry Conferences, Inquiries, Legal Costs, Business Practices, transparency, hedge funds, Policy Makers, Regulators, Proprietary Investment Data, Systemic Risk Assessment, Over-the-Counter Derivatives Markets, Disclosure, Third-Party, oversight, Private Offering, prime brokers, Auditors, General Solicitation, General Advertising, Fraud, Unsophisticated Investors, Ban on General Solicitation, Protecting Investors: A Half Century of Investment Company Regulation, Division of Investment Management, Investor Criteria, qualified purchasers, Division of Corporation Finance, Anti-Fraud Provisions, Wealth Tests, Federal Securities Laws, Chairman Schapiro, Congressman Darrell Issa, House Committee on Oversight and Government Reform, Investor Protection, capital formation, Inadvertent Violation, Waiting Period, Consulting Firm, Subscription Agreement,

Comment Letter to FSOC on Proposed Rules and Related Guidance on the Criteria for Designating Systemically Significant Nonbank Financial Institutions12.19.11


MFA submitted a comment letter to the Financial Stability Oversight Council regarding proposed rules to designate nonbank financial companies as […]