MFA Comment Letters

Topic: cost-benefit analysis

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 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 […]

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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,

MFA Submits Letter to CFTC on Proposed Rules on Enhancing Customer Protections02.15.13


MFA submitted a comment letter to the Commodity Futures Trading Commission (CFTC) on its proposed rulemaking on “Enhancing Protections Afforded […]

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (“CFTC”) on its “Proposed Interpretive Guidance […]

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Topics: accredited investors African Development Bank, AIMA, Alternative Investment Management Association, Asian Development Bank, banks, Business Conduct Standards, buy-side firms, CFTC, chief compliance officer, clearing, collective investment vehicles, comment letter, Commodity Futures Trading Commission, commodity pool, commodity pool operator, commodity swaps, compliance costs, Corporation, cost-benefit analysis, Council of the European Union, counterparties, CPO, CPO registration requirements, Dealer, dealers, Department of the Treasury, derivatives, derivatives markets, direct or indirect ownership, duplicative regulation, entity-level requirement, ESMA, estate, European Parliament, European Securities and Markets Authority, execution, fiduciary, financial crisis, financial stability, financial system, foreign banks, foreign entity, Form CPO-PQR, fund, fund of funds, G20, G20 commitments, general partnerships, hedge fund administrator, hedge fund industry, hedge fund managers, Hong Kong, Hong Kong Monetary Authority, income tax, Inter-American Development Bank, International Bank for Reconstruction and Development, international harmonization of regulations, International Monetary Fund, International Organization of Securities Commissions, interpretive guidance, IOSCO, Jill Sommers, joint-stock company, limited liability companies, listed entity, Look Through, major swap participants, majority ownership, margining, market impact, market participants, Monetary Authority of Singapore, MSPs, natural person, non-U.S. investment fund, non-U.S. market participants, non-U.S. persons, OTC derivatives, OTC derivatives market, over-the-counter derivatives, partnership, pension plans, Policy Makers, pooled accounts, portfolio reconciliation, prime brokers, qualified eligible person, real-time public reporting, registration, regulatory framework, regulatory requirements, reporting party, risk management, Scott O'Malia, SEC, Securities and Exchange Commission, Securities and Futures Commission, segregation, sell-side firms, shareholders, Singapore, substituted compliance, swap data recordkeeping, swap data reporting, swap data repository, swap dealer, swaps, swaps processing, third country, trade confirmations, transaction cost, transaction-level requirements, transparency, Trust, U.S. person, uncleared swaps, United Nations,

MFA Submits Letter to ESMA on Straight-Through-Processing08.05.12


On August 5, MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) to advocate for the […]

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Topics: aggregate limit Allocations, alternative liquidity providers, anti-competitive effects, anti-competitive restrictions, bid-ask spread, bilateral credit agreement, bilateral derivatives transactions, bilateral market, bilateral master agreements, bilateral risk management, block transactions, breakage, bundled trade, CCP, CCP Requirements Task Force, CDS, central counterparty, central limit order books, CFTC, Chicago mercantile exchange, Christopher Seagon v. Deko Marty Belgium NV, clearing, clearing acceptance process, clearing agreement, clearing member, clearing obligation, clearinghouse, CME, Commission v. Council ERTA, Commodity Futures Trading Commission, competition, competitive liquidity, Continental Cans, cost-benefit analysis, Council of the European Union, counterparty credit risk, Court of Justice of the European Union, credit default swap, credit intermediation, credit limit, credit limit order bookc, credit limits, credit risk, customer clearing documentation, DCM, DCO, dealer-to-customer platforms, dealer-to-dealer clearing, dealers, delegated acts, derivatives, derivatives clearing organization, derivatives markets, derivatives transactions, Designated Contract Market, designation notice, direct clearing members, directive, documentation, Dodd-Frank Act, due diligence, efficiency, electronic trading, EMIR, endowments, energy derivatives, ESMA, ESMA Task Forces, EU, EU Member State, European Commission, European Parliament, European Securities and Markets Authority, European Union, executing counterparty, execution, execution platform, FIA, financial stability, Financial Stability Board, financial system, FSB, futures, Futures Industry Association, futures market, ICE Clear Credit LLC, ICE energy swaps, institutional investors, interconnectedness, interest rate swap, international harmonization of regulations, International Swaps and Dealers Association, investment managers, ISDA, latency, LCH Clearnet, limit check, liquidity, liquidity fragmentation, Liquidity Providers, Major Swap Participant, Managed Funds Association, mandatory clearing, market access, market participants, matched transactions, operational market processes, operational risk, OTC derivatives, OTC Derivatives Task Force, OTC derivatives transactions, over-the-counter derivatives, pension fund, real economy, real-time acceptance, real-time processing, regulatory technical standards, risk, risk management, risk-based, SEF, settlement, straight-through processing, swap dealer, Swap Execution Facility, systemic risk, technical standards, trade repositories, Trade Repositories Task Force, trading desk, trading venues, transaction capture facility, transparency, trilateral clearing agreements, trilateral documentation, underlying clients, United States, voice execution, volatility,

MFA Submits Comment Letter to CFTC on Proposed Dodd-Frank Implementation Rules for Mandatory Swap Clearing, Trade Execution, and Margin Rules11.04.11


The OTC derivatives reforms (Title VII) resulting from the Dodd-Frank Act will cause sweeping transformation of the OTC derivatives markets […]

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Topics: active fund bilateral execution, broad-based index credit default swaps, buy-side market participants, buy-side participants, Category 1 Entities, Category 2 Entities, Category 3 Entities, Category 4 Entities, CCP, central clearing, central counterparties, CFTC, class of swaps, clearing, clearing mandate, collateral, Commodity Futures Trading Commission, commodity swaps, compliance date, compliance schedules, cost-benefit analysis, counterparties, DCMs, derivatives clearing organization, Designated Contracts Markets, Dodd-Frank Act, electronic platform, end-user exemptions, exchanges, execution, execution venue, FCM, federal register, full-scale clearing, futures commission merchants, G20, Gary Gensler, interest rate swaps, liquidity, listing, made available for trading, Major Security-Based Swap Participant, Major Swap Participant, mandatory clearing, margining, margining requirements, market participants, netting, non-dealer market participants, non-MSP counterparties, novations, OTC derivatives, over-the-counter derivatives, partial tear-ups, phased implementation, price distortion, private funds, product definition rules, prudential regulators, real-time clearing, real-time reporting, Regulators, Rulemaking, Scott O'Malia, SEC, Securities and Exchange Commission, Security-Based Swap Dealer, security-based swap SEF, security-based swaps, SEF, swap data, swap dealer, swap execution facilities, swap transaction, swap transaction compliance, swaps, systemic risk, third-party subaccount, trade execution, trading documentation, transparency, uncleared swaps, variation margin, voluntary clearing,

Supplementary Letter to the SEC in Response to its Proposed Antifraud Rule with Respect to Security-Based Swaps03.29.11


MFA submitted a letter to supplement our December 23, 2010 letter to the SEC in response to its proposed antifraud […]

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Topics: anti-fraud rule assignment, assignments, automatic stay provisions, Bank of International Settlements, Bankruptcy Code, bankruptcy proceedings, bilateral contracts, BIS, capital formation, CDS market, clearing agreement, collateral, competition, context, conveyance of rights/obligations, corporate actions, corporate loans, cost-benefit analysis, counterparty defaults, credit default swaps, credit events, credit exposure, Deception, definitions, derivatives market, disruption events, equity exposure, equity linked forwards, equity-linked swaps, exchange, execution, extinguishment of rights/obligations, fair dealing, FCIC, financial crisis, Financial Crisis Inquiry Commission, Financial Stability Board, Fraud, high yield bonds, honest markets, institutional leveraged loans, interim payments, International Swaps and Derivatives Association Inc, investment grade bonds, investment grade loans, investor confidence, ISDA master agreement, LBO-related loans, legitimate market activity, legitimate market participation, leveraged loans, Loan market Review, Manipulation, material dislocation, material non-public information, maturity date, non-index multi-name credit default swaps, novations, premium payments, price discovery, price discovery process, price efficiency, primary debt issuance, primary participant, purchase, Reuters, sale, SEC, SEC v. Rotech, secondary participant, Securities and Exchange Commission, Securities Industry and Financial Markets Association, security based swap anti-fraud rule, security based swaps market, security-based swaps, single name credit default swaps, spread payments, statutory authorization, swap market, swaps market, systemic risk, termination, termination events, The Loan Syndications and Trading Association, total return swaps, transfer of rights/obligations, transferor, unallocated swaps, underlying shares, unwinds, US OTC derivatives market,
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