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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MFA Letter to IRS Regarding Compliance Issues for Private Investment Funds Filing a Foreign Bank and Financial Accounts Report05.13.09


MFA submitted a letter as a follow up to its meeting on April 7 with officials from the IRS to […]

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Topics: FBAR Requirements private investment funds, Internal Revenue Service, IRS, Foreign Bank and Financial Accounts Reports, hedge funds, prior submissions, Patton Boggs LLP, Office of Chief Counsel, regulations, covered financial accounts, U.S. tax-exempt investors, master-feeder structures, domestic feeder fund, group filings, Form TD 90-22.1, cost-efficient, Fund Managers, compliance, adverse guidance, Glen Kirkland, IRS Reports Clearance Officer, OMB No. 1545-2038, limited liability companies, signature authority, taxpayer identification number, banks, publicly-traded corporations, tax-exempt organization, SRZ, Partnerships, bonds, notes, stock certificates, equity interest, John G. Gaine, Don Carbaugh, Financial Crimes Enforcement Network, FinCEN, United States Department of the Treasury, William Langford, federal tax return, Form TDF 90-22.1, Detroit Computing Center of the Internal Revenue Service, private equity, domestic limited partnerships, domestic limited liability companies, flow through, brokerate accounts, foreign currencies, foreign securities, interpretive guidance, general definitions, derivatives, savings, demand, checking, deposit, mutual fund, illiquid, lock-up periods, tax forms, Form 990, Form 990-PF, Form 5500, Form 1040, schedule B, Question 7a, Form 1065, Question 9, Form 1120, Schedule N, Questioon 6a, AML program rule, pooled interest, control the disposition, Form TD F 90-22, Betty Santangelo, Nancy Rose, Carl E. Kennedy, Don Moorehead, commodity trading advisors, commodity pool operators, legislators, President's Working Group on Financial Markets, PWG, Side-by-Side Structure, board directors, filing exception, FBAR, Schulte Roth & Zabel LLP, federal register,

MFA Letter to UK Financial Services Authority to Proposed Short Selling Disclosure Measures05.08.09


MFA submitted a letter to the U.K. Financial Services Authority in response to its proposed short selling disclosure measures, recommending […]

MFA Comments in Response to the IOSCO Consultation Report on Hedge Funds Oversight04.30.09


MFA submitted a written response to the IOSCO Consultation Report on Hedge Funds Oversight. MFA’s comments focused on four key […]

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Topics: Technical Committee of the Internationl Organization of Securities Comissions IOSCO, Hedge Funds Oversight: Consulation Report, global crisis, investor confidence, capital markets, Market Confidence, stability, hedge funds, systemic risk, market integrity, Investor Protection, regulation, private pools, capital, Task Force on Unregulated Financial Entities, standardized disclosures, minimum capital requirements, liquidity, price efficiency, global integration, counter-cyclical force, buyers, distressed assets, sellers, selling short, equities, pension plans, endowments, European Commission, EC, alternative investment fund managers, prime brokers, residential mortgage lending, Lehman Brothers, mutual fund, banking, Financial Research Corp. counterparties, Long Term Capital Management, Lord Adair Turner, U.K. Financial Services Authority, FSA, diligence process, Anti-Fraud Provisions, securities laws, transparency, customer collateral, performance compensation, advisory relationships, high-water mark, management fee, insider trading, MFA's Sound Practices for Hedge Fund Managers, over-the-counter derivatives, credit default swaps, CDS, absolute return, Operations Management Group, OMG, Commission Bancaire of France, bilateral solutions, business-process objectives, Fannie Mae, Freddie Mac, equity derivative confirmations, centralized clearing, clearinghouse platforms, President's Working Group's Asset Managers' Committee, Alternative Investment Management Association, Hedge Fund Standards Board, Financial Stability Forum, best practices, public disclosure, proprietary information, moral hazards, orderly dissolution, Rulemaking, G-20, OTC derivatives, Federal Reserve Bank of New York,

MFA Comments to CFTC on Proposed Rulemaking on Significant Price Discovery Contracts on Exempt Commercial Markets02.10.09


MFA submitted comments to the CFTC regarding its proposed rulemaking on significant price discovery contracts on exempt commercial markets.  MFA […]

MFA Letter to GAO Following Telephone Interview on January 15, 200902.06.09


MFA submitted a letter to the Government Accountability Office (GAO) following its telephone interview on January 15, which was held […]

MFA Letter to IOSCO Technical Committee Short Selling Task Force on Regulatory Approaches to Short Selling12.23.08


MFA sent a letter to the IOSCO Technical Committee Short Selling Task Force providing comments to regulatory approaches to short […]

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Topics: International Organization of Securities Commissions Technical Committee of the International Organization of Securities Commissions, Martin Wheatley, John G. Gaine, short selling, international harmonization of regulations, Securities and Exchange Commission, SEC, market participants, institutional investors, Florence Harmon, price discovery, market bubbles, market liquidity, liquidity, hedging, risk management, upward market manipulations, derivatives, derivatives trading, capital markets, over-the-counter derivatives, OTC derivatives, listed derivatives, convertible bond, distressed companies, "delta" hedge, capital raising, naked short selling, locate, settlement, settlement date, FINRA, Financial Industry Regulatory Authority, broker-dealer, systematic disturbances, risk, closed-out, trade reconciliation, prime broker, algorithmic trading, executing brokers, registered market centers, threshold security, bid-ask spreads, uptick rule, decimal pricing, high-volume trading, sub-penny quotes, Equity Security, sell-side firms, buy-side firms, hard to borrow shares, easy to borrow shares, long positions, reconciliation, exchanges, short squeeze, pre-borrow requirement, market efficiency, Pre-borrow Emergency Order, automated systems, manual trading, securities depositaries, custodian banks, Continuous Net Settlement, CNS, European Corporate Governance Institute, Yale International Center for Finance, National Securities Clearing Corporation, NSCC, clearing brokers, artificial price movements, short sale reporting, fraudulent short selling activity, manipulative naked short selling, unintentional failures to deliver, proprietary investment strategies, OTC equity securities, short interest positions, Regulation Filing Applications, Order Audit Trail System Rules, OATS, Order Tracking System, OTS, Nasdaq-listed securities, NYSE-listed securities, NYSE, Electronic Blue Sheet system, public disclosure, pensions, endowments, foundations, headline risk, alternative investment vehicles, chilling effect, transparency, reverse engineer, money managers, aggregate basis, synthetic positions, bilateral swaps, hedge, swap,