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.

Advanced Search Options

MFA Comments to IOSCO on Consultation Report on Principles for the Valuation of Hedge Fund Portfolios06.21.07


MFA submits comment letter to IOSCO on its Consultation Report on Principles for the Valuation of Hedge Fund Portfolios.

Click to expand relevant topics

Topics: IOSCO IOSCO's 2007 32nd Annual Conference, Mumbai., India, valuation of investments, hedge funds, global set of principles, conflicts of interest, investors, IOSCO Report, Investment Portfolios, hedge fund management, hedge fund managers, global alternative investment industry, advocate, absolute return strategies, public, private sector, United States, Securities and Exchange Committee, SEC, Commodity Futures Trading Commision, CFTC, Federal Reserve, Department of the Treasury, state agencies, Congress, major dealers, derivative market practices, advisory, government bodies, United Kingdom's Financial Services Authority, FSA, Securities Exchange Board of India, MFA's 2005 Sound Practices, Investor Protection, key market soundness, Management and Internal Trading Controls, Responsibilites to Investors, Valuation Policies and Procedures, Business Continutiy and Disaster Recovery, President's Working Group on Financial Markets, PWG, risk management, internal trading controls, Regulatory Controls, Transactional Practices, business continuity, disaster recovery, valuation, macro-level guidance, operational framework, risk monitoring, U.S. regulatory Filings, anti-money laundering, Checklist for Compliance Manuals, Checklist for Code of Ethics, consistency, independence, transparency, financial instruments, market prices, Instrument, organized exchanges, data vendors, governing body, third parties, mission-critical, Third Party Service Providers, investment portfolio, global capital markets, portfolio strategies, material obstacles, net asset value, NAV, Fair Value, pricing poliies and sources, price validation, financial statement close process,

MFA Comment Letter to Canadian Securities Administrators on Registration Reform06.29.07


MFA submits comments and attachment to the Canadian Securities Administrators on Canadian registration reform.

Click to expand relevant topics

Topics: British Columbia Securities Commission Alberta Securities Commission, Saskatchewan Financial Services Commission, Manitoba Securities Commission, Ontario Securities Commission, Autorite des Marches Financiers, New Brunswick Securities Commission, Register of Securities Prince Edward Island, Nova Scotia Securities Commission, Superintendent of Securities Newfoundland and Labrador, Register of Securities Northwest Territories, Register of Securities Yukon Territory, Register of Securities Nunavut, Proposed National Instrument 31-103, registration requirements, global alternative investment industry, hedge funds, fund of funds, managed futures funds, policymakers, absolute return strategies, hedge fund industry, regulatory authorities, educational outreach, alternative investment history, Commodity Futures Trading Commission, CFTC, Federal Reserve Board, Department of the Treasury, Canadian Securities Administrators', CSA, global financial marketplace, President's Working Group on Financial Markets, PWG, private pools of capital, capital markets, financial markets, liquidity, price efficiency, risk distribution, alternative investment opportunities, capital, funds, Canada, (NI31-103), alternative investment vehicles, regulation, privately offered fund, professional investment management for hedge fund managers, defined term, U.S. federal securities laws, investment company, venture capital, private equity, leveraged buyout, oil and gas, real estate funds, hedging, distressed, financing, large activist posistions, risk-adjusted performance, private equity funds, assets under management, AUM, Non-Canadian Hedge Fund Securities, capital raising, retirement plans, pension plans, exposure, international capital markets, National instrument 45-106, Prospects and Registration Exemptions, Labrador, non-resident dealers, limited market dealers, dealer registration requirements, Non-Ontario Regime, securities, Regulatory Authority, offering memorandum, offering document, Ontario Regime, prospectus exemption, disclosure obligations, dealer registration exemption, market intermediaries, flow-through analysis, adviser registration, commodity futures, non-resident exemptions, Commodity futures act, Administrative Costs, Fraud, international portfolio manager, international investment fund manager, advisers, fund units, Ontario registered dealer, registered broker-dealer, broker-dealer, exempt market trades, accredited investors, sophisticated investors, fund-of-funds, financial institutions, hedge fund consultant, private placement, White Paper, financial eligibility, standards, pooled investment products, investment sophistication, natural persons, net worth threshold, annual income threshold, private investment vehicles, accredited natural person, income tests for inflation, grandfather provision, dealer registrayion exemption, offshore investment vehicles, United Kingdom, European Union, EU, well-developed capital markets, regulatory regimes,

MFA Letter to NASD Regarding Proposed Rule on Member Private Offerings07.20.07


MFA submits comments to the NASD regarding NASD Proposed Rule 2721, Member Private Offerings, requesting that privately offered commodity pools […]

MFA Comments to IOSCO’s Call for Views on Issues That Could Be Addressed by IOSCO on Funds of Hedge Funds08.03.07


MFA submits comments in response to IOSCO’s “Call for Views on Issues that Could Be Addressed by IOSCO on Funds […]

Click to expand relevant topics

Topics: IOSCO FOHF Report, Investor Protection Issues, U.S. Funds of Hedge Funds, investment companies, Exemption, Disclosure, recordkeeping requirements, Commodity Pools, global alternative investment industry, hedge funds, managed futures funds, policymakers, absolute return strategies, private sector initiatives, hedge fund industry, United States, public sector, Federal Reserve, state agencies, Congress, private sector, major dealers, derivative market practices, international advisory and government bodies, United Kingdom's Financial Services Authority, Securities Exchange Board of India, retail investors, Full Part 4 Funds, Full Part 4 CPOs, Company Act FOHFs, IOSCO Technical Committe Standing Committee on Investment Management, retail investors' increased investment in FOHF's, IOSCO Report, Retail investment, retail market, regulatory regime, offering disclosure regime, advertising rules, Investor Protection, disclosure requirements, senior securities, management agreements, transactions, broker dealers, Financial Industry Regulatroy Authority, NASD, New York Stock Exchange, Investor Suitability, Manner of Offering, accredited investors, securities, private offering exemption, safe harbor, Public Offering, offering, mass mailings, General Solicitation, advertisement, open-end investment companies, mutual, liquidity, shareholders, periodic tender offers, high net worth requirements, qualified clients, natural person, adviser, net worth, initial investment requirements, retail funds, disclosure documents, compliance, compliance examinations, Company Act Registration, investment company, board members, interested persons, counsel, annual self-assessment, executive session, assets, bank, custody, broker-dealer, bank custodians, chief compliance officer, compliance policies and procedures, Federal Securities Laws, codes of ethics, fraudulent or manipulative practices, personal securities transactions, principal transactions, underlying fraud, outstanding voting, Affiliated Person, non-voting interests, agency transactions, asset coverage, company obligations, shares, dividends, borrowings, derivative instruments, advisory contracts, diversification, real estate, shareholder approval, breaches of fiduciary duty, compensation, registration statements, Form N-SAR, principal executive, principal financial officers, material fact, record keeping requirements, for cause examinations, sweep examinations, adviser operations, Subscription Agreement, verbatim risk of loss disclosure statements, table of contents, business background, risk factors, volatility, leverage, counterparty creditworthiness, commodities, margin obligations, fees, expenses, break-even chart, conflicts of interest, soft dollar, directed brokerage arrangements, futures brokers, tansferability and redemption rights, tax, liability, investor's capital contribution, undistributed profits, financial reporting to investors, Annual Report, Plain English Requirements, NFA Notice I-07-25, state securities regulators, statement of additional information, Company Act Disclosure Requirements, closed-end investment companies, Form N-2, prospectus, fee table, sales loads, offering price, dividend reinvestment, cash purchase plan fees, transaction fees, net assets, common shares, management fees, interest payments, borrowed funds, acquired fund fees, total annual expenses, initial investment, a 5% annual return, rask factors, public trading market, portfolio managers, Plain English Principles, glossaries, technical terms, administrators, custodians, affiliated broker, tax consequences, net asset value, capital stock, voting, liquidation, material pending legal proceedings, committee structure, ownership of shares, family of investment companies, proxy voting, independent registered public accounting firm, performance fees, securities transactions, tax status, offering prive, underwriters, legends, high risk, annual financial statements, independent public accountant, periodic statements, U.S. generally acceped accounting principles, accrual method of accounting, an oath or affirmation, unaudited semi-annual reports, fiscal period, Portfolio Holdings, advisory contract, Form N-CSR, Senior officer code of ethics, audit committee financial expert, audit, audit-related, share repurchases, U.S. GAAP, total return, futures professionals, promotional material, prospective investors, cherry picking, IOSCO Technical Committee, Securities and Exchange Commission, SEC, CFTC, Commodity Futures Trading Commission, commodity pool operator, CPO, fund of funds, Department of the Treasury, MFA's Sound Practices for Hedge Fund Managers, National Futures Association, NFA, FINRA,

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 […]

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 […]

Click to expand relevant topics

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 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 […]

Click to expand relevant topics

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,