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MFA Comment Letters

› Issues & Policy

Topic: AIF

MFA Finalizes Discussion Paper on Equivalence Under Article 13(3) of EMIR06.03.14


MFA finalized a discussion paper on equivalence issues under Article 13(3) of the European Market Infrastructure Regulation (EMIR).  In the […]

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Topics: EMIR MFA discussion paper, CFTC, Commodity Futures Trading Commission, European Union, European Commission, AIF, counterparties, third country, derivatives, central clearing, Transaction Reporting, systemic risk, customer protection, ESMA, European Securities and Markets Authority, OTC derivatives, Alternative Investment Fund, Cayman Islands, Dodd-Frank Act, central counterparty, equivalence, financial counterparty, non-financial counterparty, CCP, trade repositories, swap dealer, Security-Based Swap Dealer, offshore, AIFMD, U.S. person, interpretive guidance, bank, duplicative regulation, key trade terms, Stuart Kaswell, Roger Hollingsworth, United States Congress, swaps, derivatives contracts, SEC, Securities and Exchange Commission, Security-Based Swap, Limited Liability Company, pension, commodity pool, investment fund, collective investment vehicles, limited liability partnership, principal place of business test, nerve center, beneficial owner, majority ownership, Look Through, market participant, execution, portfolio reconciliation,

MFA Responds to UK FSA’s Consultation on Implementation of AIFMD02.01.13


MFA responded to the UK Financial Service Authority’s consultation on the implementation of the Alternative Investment Fund Managers Directive (AIFMD).  […]

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Topics: Financial Services Authority United Kingdom, FSA, Alternative Investment Fund Mangers Directive, AIFMD, transitional rule, European Union, EU, remuneration, FSA Remuneration Code, portfolio management, alternative investment funds, AIF, marketing, Fund Manager, UK financial promotion regime, disclosure requirements, transparency, depositary, single depositary, essential depositary functions, EU delegates, MiFID, MiFID firm, Markets in Financial Instruments Directive, Managed Funds Association, MFA, Securities and Exchange Commission, SEC, SEC-registration, investment advisers, adviser registration, subsidiary, risk management, minimum capital requirements, Capital Requirements Directive, banking entities, EEA credit institutions,

MFA Response to ESMA Discussion Paper on Key Concepts of the AIFMD and Types of AIFM03.23.12


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Topics: European Securities and Markets Authority ESMA, Alternative Investment Fund Mangers Directive, AIFMD, non-EU AIFM, AIFM, delegation arragement, portfolio management, MiFID, MiFID firm, contractual relationship, single AIFM, letter-box entity, AIFMD firm, AIF, insurance contracts, joint ventures, holding companies, co-investment of the manager, ownership of the underlying assets, investor discretion, open-ended funds, open-ended, closed-ended, Prospectus Directive, Member State regulation, UK open-ended investment company regime, UK Financial Services Authority, FSA, open-ended investment company, significant size, UCITS management company, UCITS, MiFID firms, credit institutions,

Comment Letter to ESMA on its Draft Technical Advice to the European Commission for Implementing AIFMD09.13.11


MFA submitted comments to ESMA on its consultation on possible implementing measures of the Alternative Investment Fund Managers Directive (AIFMD). […]

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Topics: AIFMD the directive, Level 2, third party managers, European Commission, consultation paper, AIF, UCITS Directive, MiFID, professional investors, retail investors, marketing, counterparties, prime brokers, net asset value, Article 61, AUM, AUM Calculations, mark-to-market, EU investors, sub-investment managers, Dodd-Frank, U.S. Securities and Exchange Commission, SEC, Investment Advisers Act of 1940, Advisers Act, registration, private funds, G-20, international coordination, Article 3(2), Article 9(3), professional indemnity insurance requirements, Gross Method, exposure, leverage, foreign exchange hedging position, interest rate hedging position, Box 93, Box 2, Box 1, NAV, Advanced Method, Box 13, diligence requirement, OTC transaction, securities lending agreement, repurchase agreement, Box 19, Box 29, risk management, risk limits, operational risk, portfolio management, market risk, portfolio risk, liquidity risk, gates, side pockets, redemption policy, depositaries, depositary, bespoke system, Box 78, collateral directive, Box 79, liability standards, Financial Services Authority, FSA, re-hypothecation provisions, Box 81, Box 86, due diligence, sub-custodian, Box 88, segregation, Box 89, omnibus accounts, liability regime, Box 95, Box 99, Value at Risk, VaR, Commitment Method, European Central Bank, ECB, Committee on European Securities Regulators, CESR Guidelines, credit default swap, CDS, remuneration, EU Passport, transparency, Box 106, passport regime, safe-keeping function, confidentiality, proprietary information, systemic risk, semi-annual reporting, collateral, counterparty exposures, Form PF, reporting period, generally accepted accounting principles (GAAP), Level 2 inputs, Level 3 inputs, valuation agents, underwriters, unobservable,
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