MFA Comment Letters

Related Legislation: Advisers Act

Comment Letter to the SEC on Establishment of a Registration Regime for Municipal Advisors as Required by the Dodd-Frank Act.02.22.11


MFA submitted a comment letter to the SEC in response to its proposal to establish a registration regime for municipal […]

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Topics: ABN AMRO Bank N.V. affiliate letters, ancillary services, bank deposits, CFTC regulation, commodity for future delivery, commodity trading advisors, common control, CTAs, dually-registered investment advisers, duplicative registration, exempt reporting advisers, foreign private advisers, Form ADV, Form MA, guaranteed investment contracts, investment advisers, investment advisory services, investment strategies, Kleinwort Benson Investment Management Limited, mid-sized adviser, multi-jurisdictional advisory firms, municipal advisor, municipal advisors, municipal advisory activities, municipal derivatives, municipal escrow investments, municipal financial products, municipal securities, Murray Johnstone Holdings Limited, no-action letters, option, participating affiliate agreements, pay to play rule, pooled investment vehicle, pooled investment vehicles, pools of assets, primary investors, private adviser exemption, private fund advisors, private fund managers, registered advisor, registered broker-dealer, registered CTAs, registered investment advisers, regular oversight, regulated persons, Royal Bank of Canada, SEC, SEC No-Action Letter, SEC oversight, SEC regulation, SEC resources, SEC-registered entities, Securities and Exchange Commission, securities futures product, Security-Based Swap, self-regulatory entity, solicitation, state entity, state securities commission, state-registered investment advisors, third-party solicitor, transition period for registration, Uniao de Banco de Brasileiros, venture capital funds,

Comment Letter to the Department of Labor in Response to the Departments Proposed Rule to Amend the Definition of Fiduciary Under ERISA02.03.11


MFA submitted a comment letter to the Department of Labor in response to the Departments proposed rule to amend the […]

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Topics: "may be considered" advice adverse, alternative investment vehicles, appraisal of property, appraisals, appraisers, asset-based fee compensation, bilateral agreement, California Public Employees' Retirement System, CFTC, Commodity Futures and Exchange Commission, Congress, custodians, daily mark, default, Department of Labor, derivative markets, diversification, DOL, DOL regulations, due diligence, Employee Benefits Security Administration, equity markets, equity securities, ERISA, ERISA fiduciaries, excise taxes, exemption applications, fee structure, fiduciary, fiduciary liability insurance. prime brokerage, fixed income markets, fund administration agreements, futures, general partner, general partners, good faith estimate, government safety new, hard-to-value, hedge fund manager, hedge fund managers, hedge funds, high water marks, impartial investment advice, inadvertent fiduciary status, Insurance and Investment, Internal Revenue Code, investment advisers, Investor Protection, Joseph Dear, managing member, market color, market concern, marketing services, may be considered standard, mutual understanding, net asset value, non-plan asset funds, options, overdraft coverage, pension fund, performance fee, plan asset vehicles, plan assets, pooled investment fund, pooled investment funds, pooled investment vehicles, pooled vehicle, pricing services, prime brokers, principal underwriter, private equity holdings, private investment fund, private pension, prohibited transaction provisions, purchaser, rate of return, real estate holdings, risk appetites, risk management, risk-adjusted returns, SEC, Securities and Exchange Commission, seller, selling exception, Senate Banking Subcommittee on Securities, settlement accommodations, short sales, side-pocket investments, significantly influence standard, structured products, swap counterparty, tailored advice, total returns, transaction reversal, valuation firm, valuation of assets,

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

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 […]

Comment Letter Regarding SEC Study on the Whether the Establishment of a Self-Regulatory Organization Would Improve the Frequency of Examinations of Investment Advisers12.16.10


MFA submitted a letter today providing comments to the SEC on Section 914 of the Dodd-Frank Act, which requires the […]

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Topics: assets under management broker dealers, broker-dealer, capital formation, CFTC, check-the-box, chief compliance officer, clearing, clearing agencies, Committee on Financial Services, Commodities Futures Trading Commission, compliance, Compliance Policies, counterparties, custody, Department of Labor, Department of the Treasury, derivative, derivatives trading activities, Disclosure, Dodd-Frank Act, fiduciary duty, Financial Industry Regulatory Authority, financial planners, Financial Stability Oversight Council, FINRA, forensic accounting, FSOC, hedge fund managers, initial margin, insider trading, investment activity, Investment Adviser Association and National Regulatory Services, investment adviser examination, investment advisory firm, Investor Protection, leverage, liquidation, major swap participants, msp, mutual fund, NASD, National Association of Securities Dealers, nregistered securities, Obama Administration's Financial Regulatory Reform Proposals, OCIE, Office of Compliance Inspections and Examinations, OTC derivatives, over-the-counter derivatives, over-the-counter securities markets, oversight, pension, private fund manager, purchase, registration, reporting, sale, SEC, Securities and Exchange Commission, securities lending, securities market, securities transactions, self-regulatory organization, short selling, small advisers, SRO, swap dealers, swaps, systemic risk, trading positions, traditional asset management firm, Transaction Reporting, transparency, U.S. House of Representatives, variation margin, wealth managers,
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