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 Comments to IRS on Application of FBAR to Private Investment Funds and Related Issues10.05.09


MFA submitted a letter to the IRS in response to IRS Notice 2009-62, which requests comments and recommendations concerning the […]

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Topics: Internal Revenue Service IRS, private investment funds, Reports of Foreign Bank and Financial Accounts, FBAR, hedge funds, private equity funds, Department of the Treasury, Financial Crimes Enforcement Network, FinCEN, filing obligation, foreign financial account, banks, publicly-held companies, non-public companies, chief financial officer, U.S.-based manager, Internal Revenue Code, FIRPTA, effectively connected income, financial institutions, foreign financial agencies, private sector, signatory authority, covered foreign financial account, commingled fund, Corporation, partnership, mutual funds, non-U.S. hedge fund, non-U.S. private equity fund, open-ended mutual funds, redemption terms, redemption policy, liquidity, financial accounts, New York State Bar Association, bank account, securities account, Lock-up, Tax Section of the New York State Bar Association, Neal S. Wolin, Michael Mundaca, Douglas H. Shulman, James H. Freis, third party transfers, broker-dealer, Passive Foreign Investment Companies, PFICs, PFIC shareholder filing requirements, Form 8621, Form 926, foreign corporations, Form 5471, Form 8865, U.S. tax return, Form 1065, non-U.S. hedge funds, money laundering, other authority, financial interest, master fund, hedge fund manager, Deferred Fees, hedge fund management companies, foreign prime brokerage, officer, partner, Investment Fund Managers, portfolio manager, investment officer, investment fund management company, Other Account Authority, Workbook on the Report of Foreign Bank and Financial Accounts, shareholders, investors, non-U.S. investors, primary owner, United States Person, domestic partnership, domestic corporation, domestic estate or trust, persons in and doing business in the United States, domestic taxpayers, safe harbor, U.S.-based managers,

Comment Letter Responding to SEC’s Proposal to Implement Amendments to the Advisers Act Contained in Title IV of the Dodd-Frank Act01.24.11


MFA submitted a comment letter todayto the SEC on its proposal to implement amendments to the Advisers Act contained in […]

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Topics: Securities and Exchange Commission De Minimis Amount, Investment Management, Richard H. Baker, Hearing on Industry Perspectives on the Obama Administration's Financial Regulatory Reform Proposals, Committee on Financial Services, U.S. House of Representatives, venture capital funds, private fund managers, Effective Date of Title IV, registration requirements, Mid-Sized Managers, Securities Commissioner, Exemption, hedge fund industry, Unregistered Managers, SEC-Registered Managers, Substantive Provision, effective date, net assets, Commission on Form ADV, Incentive-Based Compensation Arrangements, Hedge Fund Manager Registration Rul, performance fee, Income Thresholds, Grandfathering Provisions, equity owner, private adviser exemption, transitional relief, qualified purchaser, qualified client standard, Investment Adviser Registration Depository, IARD, SEC, Registration Process, SEC's Contract, IARD System, Duplicative Filing, NSMIA, Form ADV-T, regulatory assets under management, Proprietary Accounts of the Manager, Threshold of $25 Million, assets under management, Portfolios, investment adviser, Form ADV Part 1A, Instruction 5.b., threshold, registration, state securities commission, Mid-Sized Manager, SEC-registered investment advisers, Family Accounts, Proprietary Accounts, pooled investment vehicle, gross assets, hedge funds, leverage, collateral, counterparties, FSA, systemic risk, Basel Committee on Banking Supervision, Leverage Ratios, European Central Bank, Bank of America-Merrill Lynch, Columbia University, The Turner Review, Definition, proprietary information, valuation methodology, generally accepted accounting principles, GAAP, Debt-to-Equity, Instruction 5.b(4), Fair Value Methodology, International Accounting Standards, Difficult-to-Value Assets, Valuation Information, Private Fund Information, Compliance Risks, public disclosure, beneficial owners, Investor Protection Benefits, Fair Valu Hierarchy, Schedule D, Section 7.B.1, Proposed Items 14, 15, 17, 13 and 29, 11 and 12, $1 Billion, Incentive-Based, Excessive Compensation, banks, Credit Unions, broker dealers, assets, Proposed Items 5.A, 5.D and 5.F, Form ADV, Part 1A, Proposed Instruction 1.b., hedge fund managers, Depository Institutions, Taxpayer Money, National Securities Exchanges, Wealth and Income Requirements, Tier 1 Financial Holding Company, Compensation Structure, Unit-Linked Life Insurance,