MFA Comment Letters

Topic: compliance burden

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 […]

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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,

MFA Letter to FTC on Prohibition of Energy Market Manipulation Rule05.20.09


MFA jointly with FIA, CME Group, ICE and NFA submitted a letter to the Federal Trade Commission regarding its “Prohibition […]

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Topics: 1145 (7th Cir. 1982) 2002 WL 32135703, 2006 WL 778640 (S.D. Tex. March 24 2006), 250 N.W.2d 583 (Minn. 1976), 276 F.3d 583 (D.C. Cir. 2001), 276 F.3d at 591, 276 F.3d at 592, 420 F Supp.2d 1043 (N.D. Cal. 2006), 512 U.S. 594, 531 S.W.2d 805 (Tex. 1975), 537 U.S. 820, 546 F.2d 1361, 556 S.W.2d 420 (Ark. 1977), 677 F.2d 1137 (7th Cir. 1982), 706 (2d Cir. 1987), 823 F.2d 702, 883 F.2d 537 (7th Cir. 1989), accounts, Advanced Notice of Proposed Rulemaking, agents, agricultural feed-stocks, Agriculture Department, Amaranth, anti-manipulation protections, anti-manipulation system, Board of Trade of City of Chicago v. SEC, Board of Trade of City of Chicago v. SEC 677 F.2d 1137, Board of Trade of the City of Chicago, brokers, CBOT, CEA, CFTC, chain of precedent, Chciago Mercantile Exchange Inc., Chicago Mercantile Exch. v. SEC, Clayton Brokerage Co. v. Mouer, CME Group Inc., COMEX, commercial market, commodities, Commodity Exchange, Commodity Futures Trade Commission, commodity pool operators, commodity prices, commodity trading advisors, compliance burden, congressional grant, contract markets, contractual privity, contradictory requirements, corn, corporate disclosures, counterparties, crude oil, customer protection, DOE, Donald S. Clark, emissions credit, Energy Department, energy futures, energy markets, Environmental Protection Agency, EPA, ethanol, exclusive jurisdiction provision, exclusive jurisidiction provision, exclusive regulatory authority, false reports, Federal Energy Regulatory Commission, federal register, Federal Trade Commission, FERC, FIA, forward market business activities, fraud proscriptions, FTC, FTC v. Roberts, futures exchange, futures group, Futures Industry Association, gasoline, ICE, ICE Futures Canada, ICE Futures of Europe, ICE Futures U.S., Inc., instruments, IntercontinentalExchange, intermediaries, International Trading Ltd. v. Bell, Jeffrey Sprecher, Jerrold E. Salzman, John M. Damgard, Ken Roberts Co. v. FTC, limited-purpose national securities association, Manipulation, Market Manipulation Rulemaking, merchants, Minnesota v. Coin Wholesalers, National Futures Association, New York Board of Trade, new York Mercantile Exchange Inc., NFA, No. 01-1772, non-futures, non-petroleum based commodities, NYMEX, options trading, over-the-counter energy trading platform, Part 317, petroleum distillates, price artificiality, price discovery, price effects requirements, registered account executives, regulatory, resource limitations, safe harbor, SEC v. American Commodity Exch., SEC vs. Hopper, speculative limits, statutory authority, sugar, Thomas W. Sexton, Trichilo v. Sec'y of Health & Human Servs., U.S. Court of Appeals for the Seventh Circuit, United States Congress, US vs. Reliant Energy Services, USDA, wholesale markets, wholesale purchase, Williamson v. United States, Winnipeg Commodity Exchange,

MFA Submits Comment Letter to FSA Regarding Discussion Paper “Hedge funds: A discussion of risk and regulatory engagement”10.28.05


MFA Comment Letter to UK’s FSA re: Discussion Paper on Hedge Funds

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Topics: absolute return Absolute Return Magazine, absolute return strategies, AIMA, alternative investment industry, Alternative Investment Management Association, assets under management, AUM, bank, Ben Bernanke, Board of Governors of the Federal Reserve System, Canada, Cash Flow, cash management, CFTC, collateral, Commodity Futures Trading Commission, compliance burden, counterparties, counterparty risk management policy, credit derivatives, credit risk, dealers, Delaware, Department of the Treasury, derivatives, derivatives markets, derivatives transactions, disclosures, drawdown, due diligence, Fair Value, financial instrument, Financial Services Authority, Fraud, FSA, FTSE-250, fund of funds, GAAP, generally accepted accounting principles, global financial marketplace, Greenwich Roundtable, Guide to Sound Practices for European Hedge Fund Managers, hard-to-value, hedge fund administrator, hedge fund adviser, hedge fund industry, hedge fund managers, hedge funds, high net worth requirements, illiquidity, implications of the growth of hedge funds, industry-led initiatives, institutional investors, internal controls, internal trading controls, International Organization of Securities Commissions, International Swaps and Dealers Association, investment bank, investors, IOSCO, ISDA, leverage, liquidity, liquidity risk, London, Long Term Capital Management, managed futures funds, market participants, market risk, MFA's 2005 Sound Practices, MFA's Sound Practices for Hedge Fund Managers, NAV, net asset value, net worth, New York, novation protocol, novations, Office of Risk Assessment, offshore, operational risk, Policy Makers, pooled investment vehicle, Portfolio Diversification, portfolio manager, President's Working Group on Financial Markets, price discovery, private equity, private funds, PWG, real estate funds, Redemption, regulatory arbitrage, regulatory framework, regulatory oversight, retail funds, risk, risk management, risk position, Robert Jaeger, Roel Campos, S&P 500, SEC, Securities and Exchange Commission, segregation, self-regulatory organization, short selling, side pockets, single-manager hedge funds, soft commission, sophisticated investors, Sound Practices, SRO, stress testing, trade associations, Transactional Practices, United Kingdom, United States, valuation, venture capital,
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