MFA Comment Letters

Topic: executive officer

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 Comments to SEC Regarding Proposals to Revise Limited Offering Exemptions in Regulation D10.19.07


MFA submits a comment letter to the SEC regarding their proposals to revise the limited offering exemptions in Regulation D.

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Topics: 20% beneficial owner Accerdited Investor, accounting officers, accredited investor, accredited natural person, affiliated issuer, attorneys, bad actor disqualification provisions, beneficiaries, blue sky filing, brokers, capital, capital formation, cease and desist, committed capital, compliance, deferred compensation, director, Disqualification Provisions, Division of Enforcement, dollar-amount thresholds, dollar-amount threshols, due diligence, economic efficiency, equity owners, executive officer, federal regulations, financial eligibility standard, financial sophistication standards, flexibility, Form D, Fraud, fund principals, Future Inflation Adjustment, General Advertising, general partner, General Solicitation, global alternative investment industry, grandfather provision, Grandfathered, hedge funds, higher dollar-amount thresholds, implications of the growth of hedge funds, inflation, inflation adjustments, Interation Safe Harbor, investments tests, investor, Investor Protection, Investor relations professionals, Issuer, issuers, joint income thresholds, Joint Investments, knowledgeable employees, limited announcement, Limited Coffering Exemptions, managed futures funds, managing member, Manner of Offering, marital assets, natural persons, net worth, offering, Offerings, offers, Office of Economic Analysis, operational, policymaker, pooled investment fund, pooled investment funds, pooled investment vehicles, predecessor, primary beneficiary, private placement, private placement offerings, Private Pooled Investment Vehicle Release, privated pools of captial, promoter, Public Offerings, qualification, qualified client, Qualified Client Definition, qualified purchaser, Qualified Purchaser Definition, qualifies purchasers, recdivism, research analysts, retention tool, risk, risk/return, sale limitations, SEC, securities, Securities and Exchange Commission, senior financial, Sophisticated Investor Standards, sophisticated investors, sotck, start up company, subscription agent, Subscription Agreement, threshold, traders, traders of a fund affiliate, transaction costs, transactions, transparency, Trust Grantors, Trustees, U.S. Congress, United States,

MFA Submits Joint Letter to SEC on Proposed Revisions to Rules to Shorten Restricted Security Holding Periods09.21.07


MFA submits comments to the SEC in a joint letter with the Securities Industry and Financial Markets Association and the […]

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Topics: account managers actual knowledge standard, affiliates, aggregate resales, Aggression, alternative trading systems, asset managers, asset-backed securities, banks, basket, Baskets of Securities or Indices, bids, broker dealers, brokerage firms, business continuity, business units, buy-side, capital, Cashless Exercises, CDS, Chicago Board Options exchange, class relief, clearing brokers, client confidentiality, client driven, compliance, convertible debt, credit default swap, credit exposures, de-legending, deminimis exercise prices, derivative positions, director, disaster recovery, doctrine of fungibility, domestic issuers, equity securities, exchange traded index funds (ETF), executioms, executive officer, Financial Industry Regulatory Authority, FINRA, FINRA/NASD rule 2320, Fixed Income Exchange, Form 10 information, Form 144, Form 4, Form D filing, Former Shell Company, forward and option contractsm sales, fund of funds, Goldman Sachs & Co., Goldman Sachs II, hedge funds, hedging activities, hedging periods, holder, Holding Period, holding periods, index, information sharing, institutional holders, institutional investors, inter-dealer quotation systems, internal information barrier, International Swaps and Derivatives Association, Investor Protections, ISDA, Issuer, Jesse M. Brill, liquidity, long posistion, long-equivalent, managed futures funds, market, market makers, monitor, multiple accounts, Net Notional Amounts, New York Stock Exchange, nominal exercise prices, Nonconvertible Debt Securities, noncovertible debt, OTC derivatives, over-the-counter derivatives, Partial Hedging, pennies per share, pilot basis, portfolio managers, Portfolios, Powershares Exchange-Traded Fund Trust (ETF), pre-paid forward contracts, preferred stock, prime brokers, private capital formation, private placement, privately negotiated derivatives industry, public markets, public resales, qualified institutional buyers, Reasonale Belief, record, regulatory requirements, relevant unit, Reliance on Represenatons, resecuritization, restricted debt securities, restricted security holders, restricted security holding periods, Restrictive legends, risk management strategies, S&P 500 securities, safe harbor, SEC, securities, Securities and Exchange Commission, Securities Industry and Financial Markets Association, Securities Industry Association, security-holders, sell side, seller, shares, shell companies, short, short call option posistion, short-equivalent, SIA, SIFMA, significant costs, Single Trading Strategy, Staff Interpretive Posistions, ten percent beneficial owner, tolling, track, trading desks, transaction, Transfer Restrictions, transparency, unaffiliated seller, underwriter, usual and customary, verify, volume limitations, volume-weighted average prices, VWAP Trades,
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