MFA Comment Letters

Topic: assets under management

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: aggregation AIMA, alpha swap, alternative investment funds, Alternative Investment Management Association, alternative investment strategies, anonymity, Asset Management Group of the Securities Industry and Financial Markets Association, assets under management, AUM, Bankruptcy Code, benchmark contracts, bespoke swaps, beta swap, board of directors, British Virgin Islands Financial Services Commission, burdensome, buy-side, cash-settled contracts, Cayman Islands, Cayman Islands Monetary Authority, CCP, central clearing, central counterparties, CFTC, chilling effect, cleared swaps, collateral, Committee of Payment and Settlement Systems, Commodity Futures Trading Commission, commodity interests, Commodity Markets Council, commodity pool, commodity pool operators, commodity trading advisors, compliance, corporations, CPO, CPO delegation, Cross-Border, CTA, custody rules, customer collateral, customer protection, DCM, DCO, Dealer, dealer-to-customer platforms, derivatives clearing organization, designated contract markets, Division of Market Oversight, Division of Swap Dealer and Intermediary Oversight, Dodd-Frank Act, due diligence, EFRPs, EMIR, EU, European Commission, European Union, exchange for related position, execution, exemptive relief, FCM, FCM counterparty, Financial Conduct Authority, financial counterparty, Financial Stability Board, floor brokers, Form CPO-PQR, Form CTA-PR, Form PF, Form PQR, FSB, Full Physical Segregation, fund of funds, futures commission merchant, GAAP, gamma swap, general partner, generally accepted accounting principles, gold, haircuts, harmonization, hedge fund, hedgers, Hong Kong, illiquid assets, initial margin, insolvency, inter-dealer market, interest rate markets, International Organization of Securities Commissions, International Swaps and Derivatives Association, introducing broker, invoice spreads, IOSCO, ISDA, J. Christopher Giancarlo, JOBS Act, legal segregation with operation commingling, limited liability companies, limited partnership, liquidity, loss allocation, LSOC, made available for trading, Major Swap Participant, mandatory clearing, Mark Wetjen, market infrastructures, market participant, master agreement, MAT, MF Global Inc., MSPs, National Futures Association, natural gas, NFA, no-action relief, Obama Administration, OTC derivatives, OTC Derivatives Regulators Group, owned entities, package transactions, passive ownership, Peregrine Financial Group, physically settled, Policy Makers, position limits, President Obama, price discovery, private equity fund, private funds, private investment funds, private investment vehicles, privately offered commodity pools, proprietary trading tools, public investment fund, quarterly account statements, real estate investment trust, recordkeeping requirements, registered investment adviser, regulation, regulatory framework, regulatory requirements, risk management, Scott O'Malia, SDR, SEC, Securities and Exchange Commission, Securities and Futures Commission, SEF, segregated account, service providers, Sharon Bowen, short, SIFMA AMG, silver, speculation, spot-month position limits, straight-through processing, swap butterflies, swap curves, swap data reporting, swap data repository, swap dealer, swap execution facilities, swaps, swaptions, systemic risk, temporary interim relief, third country, Timothy Massad, trading privileges, transparency, Trust, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, U.S. Congress, U.S. Department of the Treasury, U.S. person, United States, variation margin, Vincent A. McGonagle,

MFA Submits Comments to the FSB/IOSCO on Assessment Methodologies for Non-Bank Non-Insurer Global SIFIs04.07.14


MFA submitted a comment letter to the Financial Stability Board and the International Organization of Securities Commissions in response to […]

MFA Submits Comments in Response to SEC Proposed Amendments to Regulation D, Form D and Rule 15609.23.13


MFA submitted a letter to the Securities and Exchange Commission in response to proposed amendments to Regulation D, Form D […]

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Topics: accredited investor accredited investors, Advance Form D, adviser registration, anti-fraud rules, assets under management, AUM, Ban on General Solicitation and Advertising, beneficial owners, capital formation, capital markets, cease and desist, censure, CFTC, Colorado Bar Association, commodities, Commodity Futures Trading Commission, competition, compliance, compliance costs, cost-benefit analysis, deemed compliant, derivatives, disclosure requirements, Division of Investment Management, due diligence, efficiency, eligible purchasers, Elizabeth Murphy, equity, examination process, Federal Securities Laws, Form 13F, Form ADV, Form D, Form PF, Franklin Group of Funds, Fund Sponsors, general partner, General Solicitation, general solicitation materials, Global Investment Performance Standards, harmonization, hedge fund industry, hedge fund managers, hedge funds, high net worth requirements, institutional investor, interpretive guidance, investment company, Investor Protection, investor qualification standards, issuers, JOBS Act, John Thune, knowledgeable employees, legends, liquidity, market practices, marketing materials, mutual fund, natural persons, Norm Champ, OCIE, Office of Compliance Inspections and Examinations, Pacific Mutual Life Insurance Company, performance, pitch book, PLI Hedge Fund Management Conference, pool participants, private capital markets, private fund, private fund managers, private fund offerings, private placement memorandum, private placements, proprietary information, public markets, qualified clients, qualified purchasers, Ray Garrett, registered investment adviser, registered investment companies, Regulation D, retail investors, RICs, Rulemaking, Schedule 13D, SEC, Securities and Exchange Commission, sophisticated investors, state securities regulators, statement of policy, transparency, United States Congress, Variable Life, Verification Methods,

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

MFA Files Amicus in Lehman Litigation to Support Judicial Asset Sale Process09.28.12


MFA filed an amicus brief in the Barclays Capital and LBI SIPA Trustee litigation before the Second Circuit Court of […]

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Topics: Acton v. Fullmer (In re Fullmer) Adam Levitin, Adelphia Recovery Trust v. HSBC Bank USA (in re Adelphia Recovery Trust), alternative investment industry, amicus brief, amicus curiae, Asia, assets under management, AUM, Australia, bankruptcy, Bankruptcy Code, bankruptcy court, banks, Barclays Capital, Bass v. Parsons (In re Parsons), best practices, Big Shanty Land Corp. v. Comer Props. Inc., borrowers, capital markets, Clarification Letter, contract, debtor, Ella Shenhav, endowments, Europe, Financier Worldwide, Folger Adam Security Inc. v. Dematteis/MacGregor, free and clear, Harvey Miller, Illinois, In re Cavalieri, In re Cedar Tide Corp, In re F.A. Potts & Co., In re Fehl, In re Gulf Coast Oil Corp., In re Integrated Res. Inc., In re Sapolin Paints Inc., In re Savage Indus. Inc., In re Silver Bros. Co., In re Smith, In re Weisser Eyecare Inc., institutional investors, interest rates, James W. Giddens, Kelly DePonte, LBHI, Lehman Brothers Holding Inc., Lehman Margin Cash, lenders, liquidity, litigant, Lori Fife, M.R.R. Traders Inc. v. Cave Atlantique, Managed Funds Association, Matter of Pease, Med. Malpractice Ins. Ass'n v. Hirsch (In re Lavigne), Meinwald v. Meinwald, MFA, Morgan Olson LLC v. Federico et al. (In re Grumman Olson Indus. Inc.), New York Adelphia, no-cash deal, pensions, public policy, purchaser, Richard Mikels, risk management, Rob Copeland, secondary offerings, Securities Investor Protection Corporation Trustee, SIFMA, stakeholders, transparency, U.S. Court of Appeals for the Second Circuit, United States Bankruptcy Court for the Southern District of New York, United States v. Sforza, Walker v. Lee (in re Rounds), Winston Inn & Rest. Corp. v. DeMichiel (In re Winston Inn & Rest. Corp.),

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