MFA Comment Letters

Topic: alternative investment vehicles

Letter to ERISA Advisory Council on Hedge Funds’ Benefit to Pensions and Beneficiaries11.01.11


MFA submitted a written statement to the ERISA Advisory Council in connection with an Advisory Council meeting on November 8 […]

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,

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

MFA Letter to IOSCO Technical Committee Short Selling Task Force on Regulatory Approaches to Short Selling12.23.08


MFA sent a letter to the IOSCO Technical Committee Short Selling Task Force providing comments to regulatory approaches to short […]

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Topics: "delta" hedge aggregate basis, algorithmic trading, alternative investment vehicles, artificial price movements, automated systems, bid-ask spreads, bilateral swaps, broker-dealer, buy-side firms, capital markets, capital raising, chilling effect, clearing brokers, closed-out, CNS, Continuous Net Settlement, convertible bond, custodian banks, decimal pricing, derivatives, derivatives trading, distressed companies, easy to borrow shares, Electronic Blue Sheet system, endowments, Equity Security, European Corporate Governance Institute, exchanges, executing brokers, Financial Industry Regulatory Authority, FINRA, Florence Harmon, foundations, fraudulent short selling activity, hard to borrow shares, headline risk, hedge, hedging, high-volume trading, institutional investors, international harmonization of regulations, International Organization of Securities Commissions, John G. Gaine, liquidity, listed derivatives, locate, long positions, manipulative naked short selling, manual trading, market bubbles, market efficiency, market liquidity, market participants, Martin Wheatley, money managers, naked short selling, Nasdaq-listed securities, National Securities Clearing Corporation, NSCC, NYSE, NYSE-listed securities, OATS, Order Audit Trail System Rules, Order Tracking System, OTC derivatives, OTC equity securities, OTS, over-the-counter derivatives, pensions, Pre-borrow Emergency Order, pre-borrow requirement, price discovery, prime broker, proprietary investment strategies, public disclosure, reconciliation, registered market centers, Regulation Filing Applications, reverse engineer, risk, risk management, SEC, Securities and Exchange Commission, securities depositaries, sell-side firms, settlement, settlement date, short interest positions, short sale reporting, short selling, short squeeze, sub-penny quotes, swap, synthetic positions, systematic disturbances, Technical Committee of the International Organization of Securities Commissions, threshold security, trade reconciliation, transparency, unintentional failures to deliver, uptick rule, upward market manipulations, Yale International Center for Finance,

MFA Comments to SEC on Semiannual Regulatory Agenda07.05.07


MFA submits comments to the SEC on its semiannual regulatory agenda, urging the Commission to add to its agenda a […]

MFA Comment Letter to Canadian Securities Administrators on Registration Reform06.29.07


MFA submits comments and attachment to the Canadian Securities Administrators on Canadian registration reform.

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Topics: (NI31-103) absolute return strategies, accredited investors, accredited natural person, Administrative Costs, adviser registration, advisers, Alberta Securities Commission, alternative investment history, alternative investment opportunities, alternative investment vehicles, annual income threshold, assets under management, AUM, Autorite des Marches Financiers, British Columbia Securities Commission, broker-dealer, Canada, Canadian Securities Administrators', capital, capital markets, capital raising, CFTC, commodity futures, Commodity futures act, Commodity Futures Trading Commission, CSA, dealer registration exemption, dealer registration requirements, dealer registrayion exemption, defined term, Department of the Treasury, disclosure obligations, distressed, educational outreach, EU, European Union, exempt market trades, exposure, Federal Reserve Board, financial eligibility, financial institutions, financial markets, financing, flow-through analysis, Fraud, fund of funds, fund units, fund-of-funds, funds, global alternative investment industry, global financial marketplace, grandfather provision, hedge fund consultant, hedge fund industry, hedge funds, hedging, income tests for inflation, international capital markets, international investment fund manager, international portfolio manager, investment company, investment sophistication, Labrador, large activist posistions, leveraged buyout, limited market dealers, liquidity, managed futures funds, Manitoba Securities Commission, market intermediaries, National instrument 45-106, natural persons, net worth threshold, New Brunswick Securities Commission, Non-Canadian Hedge Fund Securities, Non-Ontario Regime, non-resident dealers, non-resident exemptions, Nova Scotia Securities Commission, offering document, offering memorandum, offshore investment vehicles, oil and gas, Ontario Regime, Ontario registered dealer, Ontario Securities Commission, pension plans, policymakers, pooled investment products, President's Working Group on Financial Markets, price efficiency, private equity, private equity funds, private investment vehicles, private placement, private pools of capital, privately offered fund, professional investment management for hedge fund managers, Proposed National Instrument 31-103, Prospects and Registration Exemptions, prospectus exemption, PWG, real estate funds, Register of Securities Northwest Territories, Register of Securities Nunavut, Register of Securities Prince Edward Island, Register of Securities Yukon Territory, registered broker-dealer, registration requirements, regulation, regulatory authorities, Regulatory Authority, regulatory regimes, retirement plans, risk distribution, risk-adjusted performance, Saskatchewan Financial Services Commission, securities, sophisticated investors, standards, Superintendent of Securities Newfoundland and Labrador, U.S. federal securities laws, United Kingdom, venture capital, well-developed capital markets, White Paper,
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