MFA Comment Letters

Topic: disclosure requirements

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 Submits Comments to ESMA in Response to Draft Technical Standards on OTC Derivatives, CCPs and Trade Repositories03.19.12


MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) in response to its Discussion Paper on […]

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Topics: ADR aggregation, alternative liquidity providers, American Depository Receipt, back testing, back-to-back arrangements, bespoke and customized transactions, Cayman Islands, CCP, CCP Board, CCP committee, CCP data, CCP governance arragements, CCP's margin models, CCPs governance structure, central clearing, central counterparty, CFTC, chief compliance officer, chief risk officer, chief technology officer, clearing, clearing member, clearing members, clearing obligation, client clearing models, clients, Commodity Futures Trading Commission, competitive execution, confidence interval, confidentiality agreements, confidentiality of counterparty identities, conflicts of interest, counterparty and operational risk, counterparty credit risk, credit intermediary, credit intermediation, default, derivatives market, disclosure requirements, disclosure thresholds, Dodd-Frank Act, electronic trading, electronically processed, EMIR, ESMA, ESMA Discussion Paper on Draft Technical Stanards for the Regulation on OTC Derivatives CCPs and Trade Repositories, EU, EU member currency, Euro, European Securities and Markets Authority, European Union, executing counterparty, execution documentation, execution platform, extraterritorial application of EMIR, FCM, FIA, FIA-ISDA Cleared Derivatives Execution Agreement, foreign exchange derivatives, fund domicile, futures commission merchant, Futures Industry Association, guarantor, Hong Kong, indirect clearing, indirect clearing models, indirect contractual arrangements, interest rate derivatives, international harmonization of regulations, International Swap Derivatives Association, ISDA, liquidation period, lookback period, manager domicile, margin levels, margin requirements, market integrity, market location, market oversight, non-dealer representatives, non-default clearing members, notional amount, OTC derivatives, OTC derivatives market, over-the-counter derivatives, portability, principal of business, privacy and confidentiality of information, public dissemination of information, real-time processing, reasonably liquid traded instruments, record keeping, reference entity domicile, reference security, risk committees, risk management expertise, SD, SEC, Securities and Exchange Commission, security-based swaps, segregation, settlement currency, sound governance requirements, straight-through processing, stress tesing, sublimit, swap dealer, systemic risk, technical standards, third country counterparities, third country entities, trade acknowledgment, transaction volumes, underlying instrument,

Comment Letter to ESMA on Short Selling and Credit Default Swap Regulation01.10.12


MFA submitted a comment letter on January 10 to the European Securities and Markets Authority (ESMA) regarding the implementation of […]

MFA Comments to SEC on FINRA Regulation of Compensation, Fees and Expenses in Public Offerings of Real Estate Investment Trusts and Direct Participation Programs06.04.08


MFA submitted a comment letter to the SEC on FINRA’s rule 2810 with respect to trail commissions along with the […]

MFA Comments to IOSCO’s Call for Views on Issues That Could Be Addressed by IOSCO on Funds of Hedge Funds08.03.07


MFA submits comments in response to IOSCO’s “Call for Views on Issues that Could Be Addressed by IOSCO on Funds […]

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Topics: a 5% annual return absolute return strategies, accredited investors, accrual method of accounting, acquired fund fees, administrators, advertisement, advertising rules, adviser, adviser operations, advisory contract, advisory contracts, affiliated broker, Affiliated Person, agency transactions, an oath or affirmation, annual financial statements, Annual Report, annual self-assessment, asset coverage, assets, audit, audit committee financial expert, audit-related, bank, bank custodians, board members, borrowed funds, borrowings, breaches of fiduciary duty, break-even chart, broker dealers, broker-dealer, business background, capital stock, cash purchase plan fees, CFTC, cherry picking, chief compliance officer, closed-end investment companies, codes of ethics, committee structure, commodities, Commodity Futures Trading Commission, commodity pool operator, Commodity Pools, common shares, Company Act Disclosure Requirements, Company Act FOHFs, Company Act Registration, company obligations, compensation, compliance, compliance examinations, compliance policies and procedures, conflicts of interest, Congress, counsel, counterparty creditworthiness, CPO, custodians, custody, Department of the Treasury, derivative instruments, derivative market practices, directed brokerage arrangements, Disclosure, disclosure documents, disclosure requirements, diversification, dividend reinvestment, dividends, executive session, Exemption, expenses, family of investment companies, Federal Reserve, Federal Securities Laws, fee table, fees, Financial Industry Regulatroy Authority, financial reporting to investors, FINRA, fiscal period, FOHF Report, for cause examinations, Form N-2, Form N-CSR, Form N-SAR, fraudulent or manipulative practices, Full Part 4 CPOs, Full Part 4 Funds, fund of funds, futures brokers, futures professionals, General Solicitation, global alternative investment industry, glossaries, hedge fund industry, hedge funds, high net worth requirements, high risk, independent public accountant, independent registered public accounting firm, initial investment, initial investment requirements, interest payments, interested persons, international advisory and government bodies, investment companies, investment company, Investor Protection, Investor Protection Issues, Investor Suitability, investor's capital contribution, IOSCO, IOSCO Report, IOSCO Technical Committe Standing Committee on Investment Management, IOSCO Technical Committee, legends, leverage, liability, liquidation, liquidity, major dealers, managed futures funds, management agreements, management fees, Manner of Offering, margin obligations, mass mailings, material fact, material pending legal proceedings, MFA's Sound Practices for Hedge Fund Managers, mutual, NASD, National Futures Association, natural person, net asset value, net assets, net worth, New York Stock Exchange, NFA, NFA Notice I-07-25, non-voting interests, offering, offering disclosure regime, offering price, offering prive, open-end investment companies, outstanding voting, ownership of shares, performance fees, periodic statements, periodic tender offers, personal securities transactions, Plain English Principles, Plain English Requirements, policymakers, Portfolio Holdings, portfolio managers, principal executive, principal financial officers, principal transactions, private offering exemption, private sector, private sector initiatives, promotional material, prospective investors, prospectus, proxy voting, Public Offering, public sector, public trading market, qualified clients, rask factors, real estate, record keeping requirements, recordkeeping requirements, registration statements, regulatory regime, retail funds, Retail investment, retail investors, retail investors' increased investment in FOHF's, retail market, risk factors, safe harbor, sales loads, SEC, securities, Securities and Exchange Commission, Securities Exchange Board of India, securities transactions, Senior officer code of ethics, senior securities, share repurchases, shareholder approval, shareholders, shares, soft dollar, state agencies, state securities regulators, statement of additional information, Subscription Agreement, sweep examinations, table of contents, tansferability and redemption rights, tax, tax consequences, tax status, technical terms, total annual expenses, total return, transaction fees, transactions, U.S. Funds of Hedge Funds, U.S. GAAP, U.S. generally acceped accounting principles, unaudited semi-annual reports, underlying fraud, underwriters, undistributed profits, United Kingdom's Financial Services Authority, United States, verbatim risk of loss disclosure statements, volatility, voting,
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