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MFA Comment Letters

› Issues & Policy

Related Legislation: Transparency Directive

MFA and AIMA Submit Joint Letter to ESMA in Response to Call for Evidence on Short Selling Regulation03.15.13


MFA and AIMA jointly submitted a comment letter to ESMA responding to its Call for Evidence regarding its evaluation of […]

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Topics: ESMA European Securities and Markets Authority, AIMA, Alternative Investment Management Association, European Parliament, Council of the European Union, short selling, credit default swap, CDS, short selling regulation, Europe, equity, assets under management, AUM, harmonization, competent authorities, reporting requirements, short positions, European Commission, operational challenges, short selling bans, market participants, securities, sovereign issuer, capital, liquidity, price discovery, market distortions, hedging, risk, sovereign debt, Latvia, bond, sovereign bonds, EU Member State, futures, futures market, public disclosure, stock, reverse engineer, efficiency, short squeeze, volatility, reporting obligation, T+1 reporting, hedge funds, price formation, corporate issuer, Lehman Brothers, duration, delta, derivatives, share capital, index derivatives, AIFMD, MiFID, EMIR, net short position, Belgium, Finland, Germany, Netherlands, BaFin, United Kingdom, Commissione Nazionale per le Societa e la Borsa, Committee of European Securities Regulators, CESR, issued share capital, T+2, Bundesanstalt fur Finanzdienstleistungsaufsicht, settlement, locate, prime broker, index, third party managers, technical standards, non-EU investment firms, extraterritoriality, reasonable expectation, uncovered sovereign CDS, eurozone, mark-to-market, single-name CDS, France, Spain, Italy, trading volume, Steven Maijoor, bid-ask spreads, price efficiency, derivative instrument, depositary receipts, London Stock Exchange, PRNewswire, Stock Exchange Daily Official List, compliance, market disruption, interpretive guidance,

MFA Submits Comments on AIFMD Remuneration09.27.12


MFA submitted comments to the European Securities and Markets Authority (ESMA) on its consultation on guidelines on sound remuneration policies […]

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Topics: ESMA European Securities and Markets Authority, remuneration, consultation paper, remuneration policies, AIFMD, European Union, EU, Policy Makers, proportionality principle, AIFM, excessive risk-taking, Identified Staff, limited liability partnership, LLP, management committees, junior partner, RemCo, deferral of remuneration and pension, European Commission, Council of the European Union, European Parliament, hedge fund managers, financial institutions, deposit-taking entity, government insurance, private placement, institutional investor, sophisticated investors, bank, Insurance, alignment of interests, owner-managed AIFM, shareholders, public shareholders, third country, Regulators, carried interest, fees, service providers, commissions, delegate, performance fee, Senior Management, investors, other risk taker, risk profile, Balance Sheet, own account dealer, operational risk, United Kingdom, affiliated group, governing body, Limited Liability Company, LLC, risk management, compliance, audit, compliance staff, counsel, chief compliance officer, control functions, parent company, credit institutions, capital requirements, MiFID, MiFID firms, distributions, minimum capital requirements, management bodies, non-executive directors, hedge funds, assets under management, AUM, Member State, Member State competent authorities, control function, pension, variable remuneration, risk alignment, material risk, UCITS, performance measures, deferred remuneration, non-deferred remuneration, Claw-Back, fee structure, redemption rights, tax, Tax Implications, bonuses, underperformance, alternative instruments, retention policy, financial stability, non-EU AIFM, marketing, EU Passport, private placement regime, Disclosure, Annual Report, Confidential Information, stakeholders,

Comment Letter to European Commission on Proposals Relating to Short Selling07.09.10


MFA submitted a letter to the European Commission in response to its Consultation Paper on Short Selling. In our letter, […]

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Topics: European Commission EC, short selling, Investment Management, hedge funds, funds of funds, managed futures funds, absolute retrun strategies, European Union, EU, Member State regulator, liquidity, banks, prime brokerage, custody, financing, execution, public disclosure, bid-ask spreads, naked short sales, naked short selling, uncovered short selling, CESR, risk management, transaction costs, price discovery, price corrections, EDHEC Risk and Asset Management Research Centre, Oliver Wyman, market efficiency, herding, copycat behavior, pension, endowment, Foundation, retail fund, individual position disclosures, institutional investors, exchanges, trading platforms, clearing, buy in procedures, settlement failures, market makers, Securities and Exchange Commission, SEC, credit default swaps, CDS, capital markets, hedging, highly correlated share prices, convertible bonds, short squeeze,

MFA Response to CESR Consultation Paper on a Proposal for a Pan-European Short Selling Disclosure Regime10.01.09


MFA submitted a letter to the Committee of European Securities Regulators (CESR) today in response to its Consultation Paper on a […]

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Topics: Committee of European Securities Regulators CESR, CESR Proposal for a Pan-European Short Selling Disclosure Regime, alternative investment managers, hedge funds, fund of funds, hybrid funds, 130/30 funds, managed futures funds, industry service providers, alternative investment industry, absolute return strategies, short selling, manipulative conduct, Market Confidence, stability, public disclosure of short positions, short positions, market volatility, price discovery, risk management, risk management function, significant adverse effect, financial services sector, investors, Issuer, market participants, de minimis, aggregated anonymised data, timeframe for reporting, transparency directive, meaningful data, short selling bans, global equity markets, academics, liquidity, bid-ask spread, price declines, materially negative impacts, market efficiency, short selling disclosure regime, equity markets, enhanced transparency, investment managers, abusive short selling practices, abusive practices, financial institutions, herding, institutional investors, retail investors, transaction costs, capital markets, free flow of information, chilling effect, alternative investment classes, Pension Funds, endowments, foundations, alternative investment vehicles, hedging strategies, capital formation, hedge, convertible arbitrage, short equity position, convertible bonds, traditional bond issuance, convertible securities, short squeeze, Reverse Engineered, trading strategies, long equity positions, exposures, Unwind, financial stocks, pricing efficiency, short selling prohibitions, European markets, large-scale short selling, extreme market conditions, negative returns, UK Financial Services Authority, FSA, securities prices, naked short selling, Journal of Finance, Credit Suisse, market stability, disclosure thresholds, private reporting, flagging short sales, Financial Regulatory Authority, FINRA, flagging regime, disproportionate costs, real time information, over-the-counter transactions, exchanges, trading platform, settlement, physical short sales transactions, EEA stock, extraterritoriality, European Union, EU, EEA equities, two-tier disclosure model, price amplification, market testing, MiFID, competent authorities, Member State competent authorities, professional secrecy, confidentiality, freedom of information regimes, harmonization, net economic short positions, transitory short position, abusive behavior, share issues, capital raising, index trading, basket trade, reporting regimes, net economic short position, asset management company, aggregation, prudential regulators, T+1 reporting, derivatives, derivative positions, delta adjusted, cumulative compliance costs, global capital markets, EU Member State, market maker, market making,
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