MFA Comment Letters

Related Rules: Regulation S

MFA Petitions the CFTC to Exclude Certain Employee Pools from the Definition of “Pool”08.30.12


MFA petitioned the CFTC to provide an exclusion from the definition of commodity “pool” for certain internally owned entities, including […]

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its “Proposed Interpretive Guidance […]

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Topics: accredited investors African Development Bank, AIMA, Alternative Investment Management Association, Asian Development Bank, banks, Business Conduct Standards, buy-side firms, CFTC, chief compliance officer, clearing, collective investment vehicles, comment letter, Commodity Futures Trading Commission, commodity pool, commodity pool operator, commodity swaps, compliance costs, Corporation, cost-benefit analysis, Council of the European Union, counterparties, CPO, CPO registration requirements, Dealer, dealers, Department of the Treasury, derivatives, derivatives markets, direct or indirect ownership, duplicative regulation, entity-level requirement, ESMA, estate, European Parliament, European Securities and Markets Authority, execution, fiduciary, financial crisis, financial stability, financial system, foreign banks, foreign entity, Form CPO-PQR, fund, fund of funds, G20, G20 commitments, general partnerships, hedge fund administrator, hedge fund industry, hedge fund managers, Hong Kong, Hong Kong Monetary Authority, income tax, Inter-American Development Bank, International Bank for Reconstruction and Development, international harmonization of regulations, International Monetary Fund, International Organization of Securities Commissions, interpretive guidance, IOSCO, Jill Sommers, joint-stock company, limited liability companies, listed entity, Look Through, major swap participants, majority ownership, margining, market impact, market participants, Monetary Authority of Singapore, MSPs, natural person, non-U.S. investment fund, non-U.S. market participants, non-U.S. persons, OTC derivatives, OTC derivatives market, over-the-counter derivatives, partnership, pension plans, Policy Makers, pooled accounts, portfolio reconciliation, prime brokers, qualified eligible person, real-time public reporting, registration, regulatory framework, regulatory requirements, reporting party, risk management, Scott O'Malia, SEC, Securities and Exchange Commission, Securities and Futures Commission, segregation, sell-side firms, shareholders, Singapore, substituted compliance, swap data recordkeeping, swap data reporting, swap data repository, swap dealer, swaps, swaps processing, third country, trade confirmations, transaction cost, transaction-level requirements, transparency, Trust, U.S. person, uncleared swaps, United Nations,

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,

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: account managers actual knowledge standard, affiliates, aggregate resales, Aggression, alternative trading systems, asset managers, asset-backed securities, banks, basket, Baskets of Securities or Indices, bids, broker dealers, brokerage firms, business continuity, business units, buy-side, capital, Cashless Exercises, CDS, Chicago Board Options exchange, class relief, clearing brokers, client confidentiality, client driven, compliance, convertible debt, credit default swap, credit exposures, de-legending, deminimis exercise prices, derivative positions, director, disaster recovery, doctrine of fungibility, domestic issuers, equity securities, exchange traded index funds (ETF), executioms, executive officer, Financial Industry Regulatory Authority, FINRA, FINRA/NASD rule 2320, Fixed Income Exchange, Form 10 information, Form 144, Form 4, Form D filing, Former Shell Company, forward and option contractsm sales, fund of funds, Goldman Sachs & Co., Goldman Sachs II, hedge funds, hedging activities, hedging periods, holder, Holding Period, holding periods, index, information sharing, institutional holders, institutional investors, inter-dealer quotation systems, internal information barrier, International Swaps and Derivatives Association, Investor Protections, ISDA, Issuer, Jesse M. Brill, liquidity, long posistion, long-equivalent, managed futures funds, market, market makers, monitor, multiple accounts, Net Notional Amounts, New York Stock Exchange, nominal exercise prices, Nonconvertible Debt Securities, noncovertible debt, OTC derivatives, over-the-counter derivatives, Partial Hedging, pennies per share, pilot basis, portfolio managers, Portfolios, Powershares Exchange-Traded Fund Trust (ETF), pre-paid forward contracts, preferred stock, prime brokers, private capital formation, private placement, privately negotiated derivatives industry, public markets, public resales, qualified institutional buyers, Reasonale Belief, record, regulatory requirements, relevant unit, Reliance on Represenatons, resecuritization, restricted debt securities, restricted security holders, restricted security holding periods, Restrictive legends, risk management strategies, S&P 500 securities, safe harbor, SEC, securities, Securities and Exchange Commission, Securities Industry and Financial Markets Association, Securities Industry Association, security-holders, sell side, seller, shares, shell companies, short, short call option posistion, short-equivalent, SIA, SIFMA, significant costs, Single Trading Strategy, Staff Interpretive Posistions, ten percent beneficial owner, tolling, track, trading desks, transaction, Transfer Restrictions, transparency, unaffiliated seller, underwriter, usual and customary, verify, volume limitations, volume-weighted average prices, VWAP Trades,
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