MFA Comment Letters

Topic: beneficial owners

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 […]

Click to expand relevant topics

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 Letter on Canadian Early Warning Reporting System07.12.13


MFA and AIMA submitted a letter to Canadian regulators in response to proposed amendments to Canada’s Early Warning System and […]

Click to expand relevant topics

Topics: activist hedge fund AIMA, Alberta Investment Management Corporation, Alberta Securities Commission, Alternative Investment Management Association, Alternative Monthly Reporting, Andrew Vollmer, ASIC, Australia, Australian Securities and Investments Commission, Australian Stock Exchange, Autorite des Marches Financiers, Bank of Canada, banks, beneficial owners, board of directors, Brian Cheffins, British Columbia Investment Management Corporation, British Columbia Securities Commission, broker-dealer, Canada, Canada Pension Plan Investment Board, Canadian Coalition for Good Governance, Canadian Early Warning Reporting System, capital markets, Chotibhak Jotikasthira, confidentiality, contracts for difference, corporate governance, cost-benefit analysis, Counterparty, derivatives, disclosure and transparency rules, disclosures, eligible institutional investor, equity securities, EWR, FCA, Financial and Consumer Affairs Authority of Saskatchewan, Financial Conduct Authority, Google Finance, hedge funds, Hedge Funds Review, hedging, institutional investors, investment company, investor reporting, Issuer, Jeffrey Gordon, Kimber Report, liquidity, London Stock Exchange, Manitoba Securities Commission, MFA, Morningstar, National Bureau of Economic Research, New Brunswick Securities Commission, New York Stock Exchange, Nickolay Gantchev, non-objecting beneficial owners, Nova Scotia Securities Commission, OMERS Administration Corporation, Ontario Securities Commission, Ontario Teachers' Pension Plan, OTC derivatives, Paul Wolfson, performance, qualified investors, regulatory regime, relevant interests, remuneration, reporting, return on assets, Reuters, Ronald Gilson, SEC, Securities and Exchange Commission, Securities Commission of Newfoundland and Labrador, securities law, SEDAR, SEDI, Seeking Alpha, shareholders, StockCharts, Stockhouse, Superintendent of Securities Northwest Territories, Superintendent of Securities Nunavut, Superintendent of Securities Prince Edward Island, Superintendent of Securities Yukon Territory, System for Electronic Document Analysis and Retrieval, System for Insider Data on Insiders, TELUS Corporation, The Caisse de depot et placement du Quebec, TMX Group Limited, total return swaps, transparency, TSX, TSX Venture Exchange, United Kingdom, voting shares, Ward Phillips & Vineberg LLP, Yahoo!Finance,

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

Click to expand relevant topics

Topics: absolute return strategies aggregate borrowings, aggregate gross asset value, alternative methodology, asset-backed securities, assets under management, audited financial statements, balance sheet value, beneficial owners, bespoke contracts, Bloomberg, borrowing arrangements, CCPs, CDS, CDX, central clearing counterparties, CFTC, clause (iii), collateral, collateral practices, commodity pool operators, commodity trading advisors, confidentiality of information, confidentiality protections, corporate bonds, Council and Office of Financial Research, counterparty exposures, CR01, creditor, currency rates, CUSIP number, DCMs, de minimis, debt securities, default rates, delta adjusted, direct clearing members, direct investments, distressed debt, Dodd-Frank Act, duration, DV01, equity derivatives, equity exposure, equity prices, FCMs, Federal Reserve System, Financial Accounting Standards Board, Financial Stability Oversight Council, five-year option, fixed advisory fees, foreign currency contracts, foreign exchange derivatives, Form 10-K, Form 10-Q, Form 13F, Form ADV, Form CPO, Form CTA-PR, Form PF, Form PF question 36, form PF questions 28 and 35, Form PQR, FSA, funds of funds, futures commission merchants, futures contracts, GAAP, generally accepted accounting principles, global regulators, GMV, gross asset value, hedge fund assets under management, hedge fund defaults, illiquid assets, inadvertent disclosure, inception class, individual certification, interconnectedness, interest rates, interpretive guidance, Investment Adviser Registration Depository, investment advisers, investment expenses, large private fund manager, lending institutions, Level 2 inputs, Level 3 inputs, leverage, liquidity management, liquidity risk, LMV, loan commitments, long positions, managed futures, margin requirements, market noise, market participants, market value, master agreement, master-feeder, maturity brackets, maturity mismatch, NAV, net asset value, net assets under management, net borrowings, non-bank financial companies, non-rated issues, notional amount, notional value of derivatives, offsetting exposure, OFR, operational capabilities, operational efficiency, other quantitative strategies, overcounting, parallel funds, parallel managed accounts, performance fees, portfolio management, prime brokers, private equity, private fund managers, private funds, privately issued convertible bonds, proposed reporting thresholds, proprietary information, proprietary methodology, public companies, qualifying fund, record owners, recordkeeping requirements, regulatory assets under management, regulatory scrutiny, rehypothecated initial margin, reporting period, repos, risk capital allocation, risk methodology, Schedule 13G, SEC, section 404, semi-annual reporting, sensitivity analyses, short borrowing, short positions, short term high quality corporate debt, short-term interest rate, short-term market fluctuations, side pocket arrangement, SMV, statistical arbitrage-equity, strategy exposure, swap contracts, synthetic borrowing, systemic risk, systemically significant, targeted requests, ten-year option, the Fed, threshold, threshold for enhanced performance, tiered reporting system, trading and investment strategies, tri-party collateral accounts, turnover rate, UK Financial Services Authority, unaffiliated third party sources, uncommitted lines of credit, undercounting, valuation methodology, Value at Risk, VaR, variation margin,

Comment Letter Responding to SEC’s Proposal to Implement Amendments to the Advisers Act Contained in Title IV of the Dodd-Frank Act01.24.11


MFA submitted a comment letter todayto the SEC on its proposal to implement amendments to the Advisers Act contained in […]

Click to expand relevant topics

Topics: $1 Billion 11 and 12, 13 and 29, 15, 17, 5.D and 5.F, assets, assets under management, Bank of America-Merrill Lynch, banks, Basel Committee on Banking Supervision, beneficial owners, broker dealers, collateral, Columbia University, Commission on Form ADV, Committee on Financial Services, Compensation Structure, Compliance Risks, counterparties, Credit Unions, De Minimis Amount, Debt-to-Equity, Definition, Depository Institutions, Difficult-to-Value Assets, Duplicative Filing, effective date, Effective Date of Title IV, equity owner, European Central Bank, Excessive Compensation, Exemption, Fair Valu Hierarchy, Fair Value Methodology, Family Accounts, Form ADV, Form ADV Part 1A, Form ADV-T, FSA, GAAP, generally accepted accounting principles, Grandfathering Provisions, gross assets, Hearing on Industry Perspectives on the Obama Administration's Financial Regulatory Reform Proposals, hedge fund industry, Hedge Fund Manager Registration Rul, hedge fund managers, hedge funds, IARD, IARD System, Incentive-Based, Incentive-Based Compensation Arrangements, Income Thresholds, Instruction 5.b., Instruction 5.b(4), International Accounting Standards, investment adviser, Investment Adviser Registration Depository, Investment Management, Investor Protection Benefits, leverage, Leverage Ratios, Mid-Sized Manager, Mid-Sized Managers, National Securities Exchanges, net assets, NSMIA, Part 1A, performance fee, pooled investment vehicle, Portfolios, private adviser exemption, Private Fund Information, private fund managers, Proposed Instruction 1.b., Proposed Items 14, Proposed Items 5.A, Proprietary Accounts, Proprietary Accounts of the Manager, proprietary information, public disclosure, qualified client standard, qualified purchaser, registration, Registration Process, registration requirements, regulatory assets under management, Richard H. Baker, Schedule D, SEC, SEC-registered investment advisers, SEC-Registered Managers, SEC's Contract, Section 7.B.1, Securities and Exchange Commission, Securities Commissioner, state securities commission, Substantive Provision, systemic risk, Taxpayer Money, The Turner Review, threshold, Threshold of $25 Million, Tier 1 Financial Holding Company, transitional relief, U.S. House of Representatives, Unit-Linked Life Insurance, Unregistered Managers, Valuation Information, valuation methodology, venture capital funds, Wealth and Income Requirements,

Comment Letter to the Canadian Securities Administrators, Responding to Proposed Amendments to National Instrument 31-103, Registration of non-Canadian Investment Fund Managers01.13.11


On January 13, MFA filed a comment letter with the Canadian Securities Administrators in response to the CSAs proposed amendments […]

MFA Comments to SEC on Pay to Play Proposal10.06.09


MFA submitted a letter to the SEC today in response to its proposal to, among other things, restrict political contributions […]

Click to expand relevant topics

Topics: academic institutions affiliated broker-dealer, agency, American Bar Association, anti-competitive effects, assets, authority, backward-looking provisions, beneficial owners, Broker, broker-dealer, California Public Employees' Retirement System, CalPERS, CalSTRS, cash solicitation, charitable institution, chief compliance officer, chilling effect, code of ethics rule, Committee on Federal Regulation of the American Bar Association, compensation arrangements, compliance burden, compliance costs, compliance procedures, Connecticut, contractual rights and obligations, covered associates, covered investment pool, de minimi exception, Dealer, direct investment, direct investors, Disclosure, disproportionately severe punishment, due diligence, executive officer, family members of covered associates, fiduciary duty, Form ADV, Foundation, fund assets, fund of funds, general partner, government assets, government entities, government official, hedge fund managers, hedge funds, Illinois, inadvertent contribution, Inadvertent Violation, inauguration or transition committee, incentive fee structure, institutional investor, instrumentality of the State, interest, investment adviser, investment advisory services, investment management industry, investment management services, investment objectives, investment services, investment techniques, legal authorities, limited partnership, liquidity, local or state political party, look-back period, look-back provision, Los Angeles City Employees' Retirement System, Los Angeles County Employees' Retirement System, management fees, marketing activities, Massachusetts, MSRB, municipal securities, municipal securities business, municipal securities principals, municipal securities professional, municipal securities representative, Municipal Securities Rulemaking Board, municipal securities underwriters, municipal underwritings, New Mexico Educational Retirement Board, New Mexico Investment Council, New York, New York City Employees' Retirement System, New York State Common Retirement Fund, offshore managers, Oklahoma, operational challenges, pay to play practices, pay to play scandals, Pennsylvania Public School Employees' Retirement System, Pennsylvania State Employment Retirement System, pension, personal political activities, placement agent, plan, platform arrangement, political action committee, political contributions, pool of assets, pooled investment vehicle, portfolio manager, pre-approval policies, pre-approval procedures, principal business unit, private fund, program, public pension plans, publicly offered securities, redemption requests, redemption rights, registered investment adviser, registered investment companies, registration, regulations, Regulators, requests for proposals, returned contribution, risk management, sales principals, SEC, Securities and Exchange Commission, securities firms, soliciting, state and federal laws, state and local entities, Teacher Retirement System of Texas, third party placement agent, third party placement agents, third party solicitors, transparency, unregistered adviser, Wall St. Journal, Washington, written compliance policies and procedures,
Results 1 - 10 of 11