MFA Comment Letters

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MFA Comments to the U.K. Hedge Fund Working Group’s Consultation Paper12.14.07


Today, MFA submitted the following response letter to the U.K. Hedge Fund Working Group on its Consultation Paper. The overall […]

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Topics: Hedge Fund Working Group consultation paper, HFWG, Sound Practices for Hedge Fund Managers, United Kingdom, global relevance, global alternative investment industry, hedge funds, funds of funds, managed futures funds, jurisdictional requirements, fund governing bodies, Third Party Administrators, board of directors, U.S. based funds, net asset value, compliance, Comply or Explain, managers, investors, counterparties, bright line test, Fund Governing Body, President's Working Group on Private Pools of Capital (PWG), Securities and Exchange Commission (SEC), offshore, non-U.S. exchanges, Irish Stock Exchange, Luxembourg Stock Exchange, regulatory implicationsm Websites, segregation, potential conflicts, third parties, Investment Policy, Risk Disclosure, potential liability, Performance Measurement Disclosure, non-marketable, illiquid securities, portfolio, marketable securities, valuation determinations, Chartered Financial Analyst Institute, Global Investment Performance Standards, independent valuation services providers, portfolio management, independent third parties, independent in-house functions, Difficult-to-Value Assets, exchange traded posistions, uncertainity, Fair Value, fire sale, Disclosure, market price, audited annual accounts, side pocket, market risk, stress testing, Governance of Operational Risk, conflicts of interest, compliance procedures, client confidentiality, Outsourcing Risk, service legal agreement, Key Performance indicators (KPis) Fund Governance Disclosure, spectrum, Market Abuse, Insider Dealing, inside information, disclosure thresholds, U.S. securities law, UK, AML, side letters, commercial terms, reconciliation errors, valuation, legal risks, regulatory risks, trade association, board of trustees, investor groups, Regulators, Lenders/Prime Brokers/Dealers, OTC market particpants, cross-market particpant working group, OTC derivatives transactions, Federal Reserve Bank of New York for OTC equity derivatives, OTC electronic transaction posistions, price sources, cherry picking, performance fee, scenario analyses, counterparty risk, netting agreements, collateral agreements, collateral calls/two way collateral posting, soft limits, Model Risk, Key man risk, one-stop shop, prime brokers, Derivative posistions, Borrowed Stock, exposure, stock lender, proxy voting policy, Alternative Investment Management Association, AIMA,

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 Submits Joint Letter to SEC on Proposed Revisions to Rules to Shorten Restricted Security Holding Periods09.21.07


MFA submits comments to the SEC in a joint letter with the Securities Industry and Financial Markets Association and the […]

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Topics: Securities and Exchange Commission SEC, Securities Industry and Financial Markets Association, SIFMA, International Swaps and Derivatives Association, ISDA, securities, banks, asset managers, privately negotiated derivatives industry, hedge funds, managed futures funds, underwriter, security-holders, broker dealers, affiliates, Issuer, public markets, Investor Protections, public resales, Holding Period, liquidity, capital, tolling, restricted security holding periods, shell companies, equity securities, hedging activities, transaction, Securities Industry Association, Jesse M. Brill, SIA, brokerage firms, institutional investors, derivative positions, holding periods, hedging periods, long posistion, long-equivalent, short, short-equivalent, disaster recovery, business continuity, prime brokers, clearing brokers, Portfolios, risk management strategies, account managers, trading desks, institutional holders, significant costs, compliance, pilot basis, Net Notional Amounts, safe harbor, private capital formation, short call option posistion, shares, relevant unit, Aggression, Single Trading Strategy, business units, buy-side, sell side, information sharing, regulatory requirements, client confidentiality, holder, monitor, record, track, verify, market, client driven, Partial Hedging, doctrine of fungibility, convertible debt, noncovertible debt, restricted debt securities, credit exposures, Goldman Sachs & Co., pre-paid forward contracts, Goldman Sachs II, forward and option contractsm sales, Baskets of Securities or Indices, basket, index, Nonconvertible Debt Securities, Fixed Income Exchange, class relief, Powershares Exchange-Traded Fund Trust (ETF), exchange traded index funds (ETF), S&P 500 securities, New York Stock Exchange, Chicago Board Options exchange, Transfer Restrictions, bids, resecuritization, domestic issuers, Reasonale Belief, Reliance on Represenatons, internal information barrier, transparency, preferred stock, asset-backed securities, inter-dealer quotation systems, VWAP Trades, volume-weighted average prices, qualified institutional buyers, usual and customary, executioms, market makers, volume limitations, FINRA/NASD rule 2320, aggregate resales, Form 144, Form 4, restricted security holders, seller, Form D filing, unaffiliated seller, director, executive officer, ten percent beneficial owner, multiple accounts, portfolio managers, Restrictive legends, de-legending, private placement, Staff Interpretive Posistions, Cashless Exercises, deminimis exercise prices, nominal exercise prices, pennies per share, Former Shell Company, Form 10 information, over-the-counter derivatives, OTC derivatives, fund of funds, credit default swap, CDS, alternative trading systems, actual knowledge standard, FINRA, Financial Industry Regulatory Authority,

MFA Submits Comment Letter to the SEC on Amendments to Rule 10502.12.07


MFA submits comments to the SEC on amendments to Rule 105

MFA Submits Comments to IOSCO on Consultation Report on Hedge Funds Offered to Retail Investors05.31.06


MFA Submits Comments to IOSCO’s “Regulatory Environment for Hedge Funds” survey

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Topics: Consultation Report on Hedge Funds Offered to Retail Investors hedge funds, The Regulatory Environment for Hedge Funds, hedge fund industry, alternative investment industry, fund of funds, managed futures funds, Securities and Exchange Commission, SEC, Commodity Futures Trading Commission, CFTC, Federal Reserve System, Department of the Treasury, United States Congress, MFA's Sound Practices for Hedge Fund Managers, MFA's 2005 Sound Practices, dealers, credit derivatives, investor, valuation, regulation, single-manager hedge funds, IOSCO, International Organization of Securities Commissions, IOSCO Technical Committe Standing Committee on Investment Management, SC5 2003 Report, Federal Securities Laws, hedge fund managers, Code of Ethics, pooled investment vehicle, private equity, venture capital, real estate funds, sophisticated investors, institutional investors, due diligence, absolute return strategies, FTSE-250, S&P 500, investment advisers, registered investment companies, RICs, private fund, client, Look Through, investment company, assets under management, AUM, commodity pool operator, CPO, futures, options contracts, futures exchange, commodity trading advisor, CTA, National Futures Association, NFA, reporting requirements, Regulation D, accredited investors, registered public offerings, implications of the growth of hedge funds, fraudulent behavior, Senate Banking Subcommittee on Securities, Fair Value, net asset value, NAV, pricing, illiquid investments, derivatives, hard-to-v, side pocket, conflict of interest,

MFA Submits Comment Letter to FSA Regarding Discussion Paper “Hedge funds: A discussion of risk and regulatory engagement”10.28.05


MFA Comment Letter to UK’s FSA re: Discussion Paper on Hedge Funds

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Topics: Financial Services Authority FSA, hedge funds, risk, regulatory oversight, alternative investment industry, United Kingdom, fund of funds, managed futures funds, hedge fund industry, assets under management, AUM, United States, Canada, New York, London, Delaware, soft commission, short selling, Securities and Exchange Commission, SEC, hedge fund adviser, Roel Campos, hedge fund managers, market participants, self-regulatory organization, SRO, regulatory framework, offshore, regulatory arbitrage, liquidity, valuation, derivatives, derivatives transactions, Fraud, implications of the growth of hedge funds, MFA's Sound Practices for Hedge Fund Managers, MFA's 2005 Sound Practices, AIMA, Alternative Investment Management Association, internal trading controls, investors, Transactional Practices, single-manager hedge funds, President's Working Group on Financial Markets, PWG, Sound Practices, risk management, internal controls, segregation, collateral, Department of the Treasury, Board of Governors of the Federal Reserve System, Ben Bernanke, Commodity Futures Trading Commission, CFTC, Guide to Sound Practices for European Hedge Fund Managers, industry-led initiatives, counterparty risk management policy, Policy Makers, pooled investment vehicle, private equity, venture capital, real estate funds, bank, investment bank, private funds, retail funds, sophisticated investors, net worth, due diligence, absolute return strategies, S&P 500, FTSE-250, Long Term Capital Management, financial instrument, leverage, global financial marketplace, market risk, credit risk, liquidity risk, risk position, portfolio manager, stress testing, cash management, Cash Flow, drawdown, Redemption, counterparties, International Organization of Securities Commissions, IOSCO, hedge fund administrator, GAAP, generally accepted accounting principles, Fair Value, net asset value, NAV, illiquidity, hard-to-value, side pockets, absolute return, Portfolio Diversification, institutional investors, high net worth requirements, price discovery, Absolute Return Magazine, Robert Jaeger, operational risk, disclosures, Greenwich Roundtable, credit derivatives, derivatives markets, International Swaps and Dealers Association, ISDA, novation protocol, dealers, novations, trade associations, Office of Risk Assessment, compliance burden,