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 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 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 […]

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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,

MFA Comments to SEC Regarding Proposals to Revise Limited Offering Exemptions in Regulation D10.19.07


MFA submits a comment letter to the SEC regarding their proposals to revise the limited offering exemptions in Regulation D.

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Topics: Limited Coffering Exemptions global alternative investment industry, hedge funds, managed futures funds, policymaker, flexibility, issuers, Accerdited Investor, accredited natural person, offers, securities, limited announcement, offering, pooled investment vehicles, transactions, Public Offerings, General Solicitation, General Advertising, investor, accredited investor, higher dollar-amount thresholds, qualification, capital, Private Pooled Investment Vehicle Release, financial sophistication standards, federal regulations, natural persons, privated pools of captial, inflation, financial eligibility standard, joint income thresholds, Office of Economic Analysis, capital formation, compliance, implications of the growth of hedge funds, Offerings, private placement offerings, qualifies purchasers, Qualified Purchaser Definition, Qualified Client Definition, marital assets, Joint Investments, qualified client, qualified purchaser, Subscription Agreement, pooled investment fund, subscription agent, sophisticated investors, United States, Future Inflation Adjustment, dollar-amount threshols, private placement, knowledgeable employees, Trust Grantors, Trustees, beneficiaries, Sophisticated Investor Standards, risk, transaction costs, economic efficiency, Investor Protection, Investor relations professionals, research analysts, attorneys, traders, brokers, traders of a fund affiliate, senior financial, operational, accounting officers, risk/return, deferred compensation, net worth, investments tests, Issuer, fund principals, pooled investment funds, retention tool, start up company, sotck, equity owners, primary beneficiary, Grandfathered, inflation adjustments, dollar-amount thresholds, grandfather provision, due diligence, committed capital, Interation Safe Harbor, transparency, Manner of Offering, sale limitations, Disqualification Provisions, predecessor, affiliated issuer, director, executive officer, general partner, managing member, 20% beneficial owner, promoter, cease and desist, Fraud, Form D, blue sky filing, bad actor disqualification provisions, recdivism, Division of Enforcement, U.S. Congress, Securities and Exchange Commission, SEC, threshold,

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 […]

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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 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 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,