MFA Comment Letters

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Letter to the European Commission in Response to its Consultation Paper, Review of the Markets in Financial Instruments Directive (MiFID)02.02.11


MFA submitted comments to the European Commission in response to its Consultation Paper, Review of the Markets in Financial Instruments […]

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Topics: European Commission Markets in Financial Instruments Directive, MiFID, regulatory framework, market stability, risk capital, proprietary strategies, surveillance tools, European Union, EU, financial regulatory system, hedge funds, OTC, commodity derivatives market, Investor Protection, title transfer collateral arrangements, non-retail clients, third country firms, "strict equivalence" regime, electronic trading platforms, liquid derivatives, exchange trading, exchange-traded products, European OTC derivatives markets, US markets, Asian Markets, ESMA, sufficiently liquid, European Commission on Standardisation and Organised Platform Trading of OTC Derivatives, Organised Trading Venues, cost-effective manner, reduced transaction costs, algorithmic trading, broker dealers, market impact, accurate price discovery, high frequency trading, HFT, market makers, low latency technology, strategy holding periods, horizon strategies, fleeting arbitrage opportunities, risk management, electronic market-making, technology-driven market makers, inventory risk, risk exposure, inter-market arbitrage, ultra low-latency technology, capital formation, automated execution technology, global connectivity infrastructure, financial institutions, market connectivity intermediaries, direct market access, flash crash, HFT trades, non-HFT trade, asset managers, insurance companies, banks, brokers, automated trading, arbitraging, minimum quantitative threshold, portfolio manager, alternative investment fund managers, AIFM directive, UCITS Directive, level playing field, non-EU asset managers, risk controls, pre-trade checks, SEC, Securities and Exchange Commission, circuit breakers, market-wide single stock circuit breakers, limit up system, limit down system, speed bumps, trading delays, specified maximum execution speeds, co-location facilities, latency, liquidity, investor confidence, technological innovation, short-term price swings, low latency technology chain, minimum tick sizes, liquid market, deep market, liquidity provision requirements, article 4(8) of MiFID, broker-dealer capital, margin requirements, concentrated risk solution, regulatory "tax, market efficiency, minimum duration of orders, limit orders, stale orders, affirmative and negative obligations, pre-trade transparency, post-trade transparency, investment strategies, safeguards, equity markets, waivers, dark pools, equity investors, pre-trade transparency waivers, order stubs, alternative trading systems, ATSs, indications of interest, IOIs, actionable IOIs, block sized trades, daily trading volume threshold, order-slicing methodologies, price discovery, post-trade reporting proposals, depositary receipts, exchange traded funds, certificates, UCITS, non-EU markets, non-EU investment firms, MiFID framework directive, non-equity instruments, comprehensive price date, comprehensive notional data, regulatory transparency thresholds, data consolidation, approved publication arrangements, APAs, European Consolidated Tape, Consolidated Tape, Congress, National Market System, composite quotation system, consolidated transaction reporting system, quotations, Consolidated Tape Association, opaque market centers, sharp shoot, order flow, US Securities Industry Automation Corporation, national best bid and offer, depth of market quotations, reporting protocols, third party information vendors, Securities Industry and Financial Markets Association, NetCoalition, Yahoo Inc, Google, Bloomberg L.P., depth-of-market fees, NetCoalition v. Securities and Exchange Commission, core date, consolidated core data, CQ plan, position-level data, harmonised position information, reasonable threshold, nexus, trader ID, transaction report, confidentiality obligation, client identifier, statutory obligation, OTC contract, trade repository, summary disclosure, ex-post disclosure, ex-ante disclosure, conflicts of interest, title transfer collateral arrangement, retail client, member states, cash balance, risk warnings, securities financing transaction, information requirements, due diligence obligations, third country regime, equivalence mechanism, strict equivalence, market disorder, systemic risk, unilateral bans, market turmoil, cost/benefit analysis, regulatory authorities, consultation papers, systemic risk grounds, CCP, capital flows, lending flows, credit flows, International Swaps and Derivatives Association, ISDA, G20, Financial Stability Board, European Market Infrastructure Regulation, EMIR, sovereign CDS, European Commission's report of Sovereign CDS, credit default swaps, CDS market, hedgers, hard position limits, physical commodity markets, market manipulation, position management, mechanical imposition, commodity derivatives, CESR, UK Treasury and Financial Services Authority, price movement, derivatives position, Disclosure, reporting obligations, transparency directive, security-based derivatives, European Commission Request for Additional Information in relation to the Review of MiFID, volatility, non-hedging, aggregate open interest/notional amount, reporting regimes, contract, market data,

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,

Comment Letter Responding to SECs Proposed Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers With Less Than $150 Million in Assets Under Management, and Foreign Private Advisers01.24.11


MFA submitted a comment letter to the SEC in response to the SECs proposal Exemptions for Advisers to Venture Capital […]

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Topics: Securities and Exchange Commission SEC, Exemptions, venture capital funds, Private Fund Advisers, assets under management, foreign private advisers, Exemptions Release, Private Fund Registration, Statutory Exemption, commodity trading advisors, Single Investor Private Funds, investor, Commodity Futures Trading Commission, commodity trading advisor, CTA, Securities-Related Advice, CFTC, Peavey Commodity Futures Fund, SEC No-Action Letter, 1983 SEC No-Act. LEXIS 2576, Tonopah Mining Co. of Nevada, 26 S.E.C. 426, Subadvisers, Subsidiary Advisers, Regulatory Authority, Investment Adviser Industry, Specialized Expertise, Foreign Advisers and Subadvisers, no-action letters, Domestic, Non-U.S. Investment Advisory Firms, Control, Participating Affiliate, Mercury Asset Management Plc., affiliate letters, Registered and Non-Registered Entities, Factual Representations, Associated Persons, Full Regulatory Access, oversight, Non-Registered Adviser, Multi-Jurisdicational Advisory Firms, Non-U.S. Activities, systemic risk, Hedge Fund Adviser Registration Rules, Unio de Banco de Brasileiros S.A., Kleinwort Benson Investment Management Limited, AMRO Bank N.V., Royal Bank of Canada, ABA Subcommittee on Private Investment Entities, Compliance and Management Structures, Non-Control, affiliated entities, U.S. law, Non-U.S. Law, Affiliated Person, Form ADV, private fund, Master-Feeder Structure, Side-by-Side Structure, Specialized Feeder, Outstanding Voting Securities, pooled investment vehicle, limited partnership, Limited Liability Company, Independent Verification of Assets Requirement, general partner, Nominal Capital Account, Limited Partner, Instrument, total return swap, Record Owner, Equity Security, prudential regulators, Secretary of the Treasury, Security-Based Swap, Staff Responses to Questions About the Custody Rule, Question VI.11, Voting Rights, Redemption, Transparency Rights, regulatory assets under management, de minimis exemption, Regulatory Assets, separate account structure, Gross Assets Calculation, Fair Value, valuation methodology,

Comment Letter Responding to FDIC’s Proposed Rules to Implement Certain Provisions of the Orderly Liquidation Authority in Title II of the Dodd-Frank Act.01.18.11


MFA filed a comment letter with the Federal Deposit Insurance Corporation (the FDIC) in response to the FDICs proposed rules […]

Comment Letter to Responding to ESMA’s Call for Evidence Regarding Level 2 Implementation of the Alternative Investment Fund Managers Directive01.14.11


On January 14, MFA submitted comments to the European Securities and Markets Authority (ESMA) in response to a call for […]

Comment Letter to the Canadian Securities Administrators, Responding to Proposed Amendments to National Instrument 31-103, Registration of non-Canadian Investment Fund Managers01.13.11


On January 13, MFA filed a comment letter with the Canadian Securities Administrators in response to the CSAs proposed amendments […]