MFA Comment Letters

Related Legislation: Exchange Act

Petition to SEC for Rulemaking on Rule 502 of Regulation D, Ban General Solicitation01.06.12


MFA submitted a comment letter to the SEC requesting that the Commission amend Rule 502(c) of Regulation D to eliminate […]

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Topics: accredited investors Administrative Costs, Anti-Fraud Provisions, Auditors, Ban on General Solicitation, Ban on General Solicitation and Advertising, Broadcast Over Television, Broker, Business Practices, capital formation, Chairman Schapiro, Competitiveness, Congressman Darrell Issa, Consulting Firm, Continuous Offerings, Disclosure, Division of Corporation Finance, Division of Investment Management, Economic Growth, Federal Securities Laws, Fraud, Fund Managers, General Advertising, General Solicitation, hedge funds, House Committee on Oversight and Government Reform, House of Representatives, Inadvertent Violation, Independent Regulatory Agencies, Industry Conferences, Inquiries, Interpretive Framework, investment company, Investor Criteria, Investor Protection, Investor Protections, Issuer, Job Creation, Legal Costs, Limited Partnerships, Offerings or Sales, Offers or Sales Securities, Over-the-Counter Derivatives Markets, oversight, Petition for Rulemaking, Policy Makers, Pre-Existing Relationship Doctrine, Pre-Existing Substantive Relationship, prime brokers, private funds, Private Funds Managers, Private Offering, Proprietary Investment Data, Protecting Investors: A Half Century of Investment Company Regulation, Public Offering, Qualified Potential Investors, qualified purchasers, Radio, Regulators, SEC, Securities and Exchange Commission, Selling Agent, Senate, sophisticated investors, Subscription Agreement, Systemic Risk Assessment, Third-Party, transparency, United States Congress, Unsophisticated Investors, Waiting Period, Wealth Tests,

Supplementary Letter to the SEC in Response to its Proposed Antifraud Rule with Respect to Security-Based Swaps03.29.11


MFA submitted a letter to supplement our December 23, 2010 letter to the SEC in response to its proposed antifraud […]

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Topics: anti-fraud rule assignment, assignments, automatic stay provisions, Bank of International Settlements, Bankruptcy Code, bankruptcy proceedings, bilateral contracts, BIS, capital formation, CDS market, clearing agreement, collateral, competition, context, conveyance of rights/obligations, corporate actions, corporate loans, cost-benefit analysis, counterparty defaults, credit default swaps, credit events, credit exposure, Deception, definitions, derivatives market, disruption events, equity exposure, equity linked forwards, equity-linked swaps, exchange, execution, extinguishment of rights/obligations, fair dealing, FCIC, financial crisis, Financial Crisis Inquiry Commission, Financial Stability Board, Fraud, high yield bonds, honest markets, institutional leveraged loans, interim payments, International Swaps and Derivatives Association Inc, investment grade bonds, investment grade loans, investor confidence, ISDA master agreement, LBO-related loans, legitimate market activity, legitimate market participation, leveraged loans, Loan market Review, Manipulation, material dislocation, material non-public information, maturity date, non-index multi-name credit default swaps, novations, premium payments, price discovery, price discovery process, price efficiency, primary debt issuance, primary participant, purchase, Reuters, sale, SEC, SEC v. Rotech, secondary participant, Securities and Exchange Commission, Securities Industry and Financial Markets Association, security based swap anti-fraud rule, security based swaps market, security-based swaps, single name credit default swaps, spread payments, statutory authorization, swap market, swaps market, systemic risk, termination, termination events, The Loan Syndications and Trading Association, total return swaps, transfer of rights/obligations, transferor, unallocated swaps, underlying shares, unwinds, US OTC derivatives market,

Comment Letter to the CFTC on its Proposed Rules on Risk Management Requirements for Derivatives Clearing Organizations03.21.11


MFA submitted a comment letter to the CFTC on its proposed rules on Risk Management Requirements for Derivatives Clearing Organizations. […]

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Topics: $50 million upper limit antitrust considerations, Bank of America-Merrill Lynch, bilateral trades, capital requirements, CFTC, Chicago Board of Trade, cleared trade volumes, clearing member, clearinghouses, Columbia University, committee on payment and settlement systems and technical committee of the International Organization of Securities Commissions, Commodity Futures Trading Commission, competition, connectivity, counterparty credit assessment practices, CPSS-IOSCO standards, credit risk, creditworthiness, cross product margin, customer initial margin, DCM, DCO, DCO concentration risk, DCO margin methodologies, default management framework, derivatives clearing organizations, Designated Contract Market, differentiated margining, direct clearing members, direct clearing members' initial margin, diversity of market participants, effective date, electronic execution, eligibility standards, excess margin, executing counterparty, fair and open access, federal register, Federal Reserve Bank of New York, five-day liquidation horizon, futures, global banking crisis, greater market concentration, guaranty fund scaling methodologies, hedge fund industry, highly liquid instruments, initial margin, initial margin requirements, investment banks, ISDA, leverage ratio, mandatory central clearing, margin, margin calculation utility, margin calls, margin methodology, margin requirements, mark-to-market variations, market liquidity, market volatility, minimum capital requirements, net capital obligation, non-hedge positions, obligations, on-the-run 10 year interest rate swaps, participant eligibility, phase-in period, portfolio margining, product eligibility, product portfolio, risk exposure, risk management, Risk Management Requirements, risk-based methodologies, scaling requirements, SEC, Securities and Exchange Commission, SEF, standard two-way protocols, stress and default scenarios, Swap Execution Facility, swap portfolio, swap portfolio size, swaps, systemic risk mitigation, The Turner Review, threshold guaranty fund contribution, tiers, transaction volume, volatility,

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,

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

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,

Comment Letter to SEC Responding to Concept Release on Equity Market Structure05.07.10


MFA submitted a letter to the SEC in response to its request for comments on its Equity Market Structure Concept […]

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Topics: algorithm alternative trading systems, asset classes, automated trading, bid-ask spreads, broker dealers, buyers, cancellation rate, capital allocation, capital formation, co-location, competitive barriers, connectivity vendors, dark pools, decimalization, Designated Market Maker, direct market access, ECN, efficiency, electronic communication networks, electronic trading desks, electronically accessibel quotes, endowments, Equity Market Structure, execution speed, fees, fixed income, foundations, France, frontrunning, Germany, global financial crisis, hedging, HFT, high frequency trading, institutional investors, insurance companies, inter-market arbitrage, Intermarket Trading System Plan, inventory risks, investment time horizon, investor confidence, ITS, Japan, large cap stocks, limit orders, liquidity, long-term investors, low latency technology, market color, market consolidation, Market Crash of 1987, market depth, market fragmentation, market maker, momentum ignition, mutual fund, Nasdaq, National Association of Securities Dealers Inc., National Market System, New York Stock Exchange, non-public trading, NYSE, Office of Economic Analysis, order anticipation, order cancellations, order handling rules, order protection rule, pensions, phantom liquidity, pinging, post-trade execution, post-trade transparency, price discovery, price swings, private investment pools, proprietary trading, public information, quantitative strategies, quote flickering, registered investment advisers, regulation ATS, Regulation NMS, retail investors, risk management, SEC, sector change, Securities and Exchange Commission, securities lending, sellers, short selling, short-term traders, small cap stocks, specialist quotes, sponsored access, spreads, technology, trading desk, trading volume, transaction costs, transparency, Treasury ETF, trends, U.S Treasury bonds, U.S. Department of Justice, United Kingdom, upstairs market, volatility,
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