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 Letter to SEC Chairman Cox Regarding Hedge Fund Transparency and Other Issues04.24.08


MFA President and CEO, Richard H. Baker, met with SEC Chairman Christopher Cox this morning and discussed the topics addressed […]

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Topics: Securities and Exchange Commission SEC, Christopher Cox, alternative investment industry, Policy Makers, Regulators, investors, hedge funds, hedge fund offerings, transparency, hedge fund investors, capital markets, systemic risk, General Solicitation, Ban on General Solicitation and Advertising, General Advertising, safe harbor, Regulation D, hedge fund managers, sophisticated investors, accredited investors, qualified purchasers, private offerings, securities, Protecting Investors: A Half Century of Investment Company Regulation, Division of Investment Management, United States Congress, Implications of the Growth of Hedge Funds Staff Report to the United States Securities and Exchange Commission, Rulemaking, advertising materials, Clover Capital no-action letter, staff guidance, no-action letters, accredited natural person, large accredited investor, Federal Securities Laws, inflation, mutual recognition, Nancy Morris, regulatory barriers, Cross-Border Investments, market participants, transaction costs, global capital markets, financial services industry, Australia, European Union, EU, Canada, broker-dealer, best practices, Sound Practices for Hedge Fund Managers, NYRO OCIE, chief compliance officer, trade associations, Commodity Futures Trading Commission, CFTC, Memorandum of Understanding, public commodity pools, National Futures Association, NFA, Financial Industry Regulatory Authority, FINRA, public commodity pool offerings, futures, futures market, pooled investment vehicle, public offering disclosure requirements, Direct Participation Programs, DPP, annual cap, lifetime cap, offering proceeds, trail commissions, managed futures, brokers,

MFA Letter to Senate Republican Capital Markets Task Force Regarding United States Capital Markets Competitiveness in the Global Financial Services Marketplace02.29.08


MFA submits a comment letter to the Senate Republican Capital Markets Task Force in response to the Task Force’s request […]

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Topics: Senate Republican Capital Markets Task Force United States Congress, capital markets, U.S. Capital Markets, global financial system, regulatory regime, tax, capital formation, capital efficiencies, financial regulatory system, principles-based regulation, Securities and Exchange Commission, SEC, regulation, non-U.S. investors, capital, hedge funds, venture capital funds, oil and gas partnerships, Strategy and Financial Innovation, Investor Protection, Financial Services Roundtable, Blue Print for U.S. Financial Competitiveness, Commodity Futures Trading Commission, CFTC, safe harbor, exchanges, market crisis, market participants, duplicative regulation, public commodity pools, National Futures Association, NFA, Financial Industry Regulatory Authority, FINRA, commodity futures markets, energy commodities, Federal Energy Regulatory Commission, FERC, natural gas futures market, Federal Trade Commission, financial services industry, President's Working Group on Financial Markets, PWG, Department of the Treasury, Secretary of the Treasury, Federal Reserve Board, assets under management, investment advisers, retail investors, prudential regulators, Henry Paulson, Office of Compliance Inspections and Examinations, OCIE, Economic Club of New York, no-action letters, General Solicitation, General Advertising, transparency, Cross-Border, U.S. immigration policies, skilled non-U.S. professional workers, H-1B visa, student visa, harmonization, generally accepted accounting principles, GAAP, International Financial Reporting Standards, IFRS, mutual recognition, Canada, Enron Corporation, Cendant, Financial Services Forum, United Kingdom, European Union, EU, chilling effect, equity markets,

MFA Submits Letter to Department fo the Treasury Regarding Review by the Treasury Department of the Regulatory Structure Associated with Financial Institutions11.21.07


MFA submits letter to the U.S. Department of the Treasury in response to its request for recommendations on how to […]

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Topics: Department of the Treasury Regulatory Structure, optimal regulatory structure, marketplace, hedge funds, managed futures funds, Policy Makers, global alternative investment industry, trading business activties, United States, state securities regulators, regulatory oversight, regulatory framework, conflicting regulatory edicts, private sector self-regulation, Sound Practices for Hedge Fund Managers, peer-to-peer guidance for hedge fund managers, valuation, Portfolios, risk management, adequate disclosure, hedge fund investors, international organizations, International Organization of Securities Commissions (IOSCO), Market Particpants, public interest, market and financial integrity, United Kingdom's Financial Services Authority (FSA), Japan's Financial Services Agency, BaFin, Australia, Netherlands, twin peaks model, prudential safety, soundness regulation, conduct-of-business, U.S. capital market competitiveness, Investor Protection, market price transparency, principles-based approach, rules-based approach, flexibility, futures exchange, derivatives clearing organizations, safe harbor, compliance, exchange, statutory core principles, uniform set of basic principles of regulation, public interest goals, customer protections, retail foreign exchange (FX), transactions, Fraud, Congress, state regulators, local law enforcement, Europe, Financial Services Action Plan, Asian Countries, regions, international regulatory standards, costs, foreign markets, competitiveness concerns, G-8 finance ministers and deputies, international portfolio valuation principles, securities, futures, intermediaries, common stock, options contracts, ownership interest, capital raising process, stock index, natural gas, gold, wheat, stock price, stock world, net long, higher prices, short, fair prices, financial products, bonds, security futures, futures contracts, underlying asset, crude oil, currency options template, trading platforms, liquid trading markets, margin area, risk-based performance bond system, margin levels, options trading, natural gas futures price manipulation, substantial inefficiency, intemediary brokerage firms, duplicative systems, unwarranted costs, portfolio margining, collateral management stystems, financial integrity systems, net capital, cross-recognition efficiencies, commodity pool operator, private pools of capital, NFA, mutual, business models, retail customers, Disclosure, public managed futures fund offerings, FINRA, futures brokerage commission payments, federal government, wholesale, commercial, hedging, derivatives, commodity pool operators, collective investment vehicles, pool offerings, tired system of regulation, private transactions, counterparites, funds, exchanges, regulation of intermediaries, Henry Paulson, financial institutions, fund of funds, Securities and Exchange Commission, SEC, CFTC, Commodity Futures Trading Commission, Financial Industry Regulatory Authority, National Futures Association, President's Working Group on Financial Markets, PWG, Financial Services Roundtable, Federal Energy Regulatory Commission, FERC,

MFA Files Joint Comment Letter to California Department of Corporations on Proposed Rule Requiring Hedge Fund Managers to Register with the State11.21.07


MFA and the Coalition of Private Investment Companies submit a joint comment letter to the California Department of Corporations on […]

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Topics: Department of Corporations California Corporate Securities Law, Coalition of Private Investment Companies, CPIC, Commisioner of the California Department of Corporations, investment advisers, California, global alternative investment industry, hedge funds, managed future funds, proposal, Congress, jobs, office rents, support services, tax revenues, Investor Protection, de minimis standard, state registration, venture capital, investment adviser, national markets, Exemption, public, registered investment companies, private offerings, initial statement of reasons, jurisdiction, implications of the growth of hedge funds, 2003 staff report, industry trends, oversight, Fraud, fund advisers, Pension Funds, privately-offered pooled investment vehicles, due diligence, accredited investors, qualified purchasers, Board of Governors of the Federal Reserve System (FED), professional asset managers, fiduciary standards, New York, London, San Francisco, Exempt Advisers, financial products, risk, start-up companies, liquidation restrictions, locked up, Redemptions, capital calls, liscensing exemption, pooled investment vehicles, accredited investor standard, Private Offering, Form D, Data, electronic filing, requirement, Investor's Committee of the Advisory Group, financial market, Industry Standards, Agreement Among PWG and U.S. Agency Principals on Principles and Guidelines Regarding Private Pools of Capital, registrant, training personal, The Bureau of National Affairs, Sound Practices for Hedge Fund Managers, spillover effect, brokerage firms, James Chanos, chief investment officer, CalPERS, California Public Employees' Retirement System, Department of the Treasury, Commodity Futures Trading Commission, CFTC, President's Working Group on Financial Markets, PWG, Securities and Exchange Commission, SEC, assets under management, AUM, fund of funds,

MFA Comments to SEC on Proposed Rule Change by American Stock Exchange to List and Trade Shares of Nuveen Commodities Income and Growth Fund10.15.07


MFA submits comments to the SEC on an American Stock Exchange (“AMEX”) rule proposal which would permit commodity pools to […]

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Topics: Securities and Exchange Commission American Stock Exchange Pursuant, Nuveen commodities Income and Growth Fund, Amex, closed-end exchange-listed commodity pool, future offerings, Portfolio Holdings, closed-end commodity pool, investor, share, liquidity, market price per share, redeemable security, surplus, Issuer, proportionate share, net assets, cash equivalent, net asset value per share, NAV, demand, supply asset-classes, investment strategies, exchange traded fund, ETF, baskets, net asset value per basket, qualified institutions, portfolio holding, disclosures, securities, daily portfolio composition information, Redemption, creation or redemption transactions, hegde, exposure, robust secondary market, index-tracking vehicles, transparency, index mutual fund, commodity pool, redeemable shares, significant premium, discount, potential harm, closed-end fund, portfolio composition rules, Commodity Futures Trading Commission, CFTC, market participants, exchange-listed pool, trading posistions, reverse engineer, front-run, National Futures Association, NFA, futures industry, Interpretive Notice, equitable principles, commodity futures business, commodity trading advisor, CTA, investment adviser, hedge funds, managed future strategies, Closed-End Registered Investment Companies, RIC, closed-end exchange-traded registered investment companies, Great Depression, exchange-traded commodity pools, continuous offering, redeemable securities, U.S. Congress, Listed Company Manual of the NYSE, SEC,

MFA Files Memorandum of Law in Support of Plaintiff CFTC’s Exclusive Jurisdiction and Defendant Amaranth Advisor’s Stay Motion10.03.07


MFA as part of the Amici Curiae Futures Group files Memorandum of Law in support of plaintiff Commodity Futures Trading […]