MFA Comment Letters

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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 […]

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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 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 SEC on Semiannual Regulatory Agenda07.05.07


MFA submits comments to the SEC on its semiannual regulatory agenda, urging the Commission to add to its agenda a […]

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.

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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 Comments to U.S. Federal Banking Agencies on Capital Treatment of Equity Investments in Hedge Funds by Banks in Proposed Regulations Implementing Basel II International Capital Accords06.21.07


MFA submits comment letter to the U.S federal banking agencies on the capital treatment of equity investments in hedge funds […]

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.

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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 Submits Comments to SEC on Proposals for Accredited Natural Person and Antifraud Rules03.09.07


MFA submits comment letter and attachment to the SEC on Proposals for Accredited Natural Person and Antifraud Rules.

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Topics: Securities and Exchange Commission SEC, private investment vehicles, Accredited Natural Person Proposal, Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles, Investor Protection, alternative investment industry, capital markets, hedge funds, managed futures funds, President's Working Group on Financial Markets, PWG, private pools, liquidity, price efficiency, risk distribution, Regulatory Structure, direct investment, Christopher Cox, Robert Steel, venture capital, private equity, industry innovation, Department of the Treasury, cash room, Randal Quarles, Senate Committee on Banking Housing and Urban Affairs, risk-adjusted performance, accredited investor standard, financial eligibility standards, accredited investor, pooled investment vehicles, net worth threshold, financial eligibility standard, Pui-Wing Tam, Jonathan Shieber, Stephen Heuser, qualified client, qualified purchaser, qualified institutional buyer, qualified eligible person, eligible contract participant, joint property, net worth, Office of Economic Analysis, 3(c)(1) funds, illiquid investments, real estate, Lock-up, U.S. economy, Stuatory Authority, 100 beneficial owners, beneficial owners, 3(c)(7) funds, deferred compensation, fund employees, American Bar Association, research analysts, legal counsel, traders, broker dealers, attorneys, brokers, compliance, operational, accounting officers, grandfathering provision, competition, start-up funds, antifraud proposal, Goldstein decision, scienter, transparency, dialogue, Request for Proposal, private placement memorandum, Limited Partnership Agreement, Subscription Agreement, due diligence, management, incentive compensation, conflicts of interest, side letters, withdrawal, transfer procedures, tax issues, ERISA Issues, Thomas Lemke,