MFA Comment Letters

Topic: Fair Value

Comment Letter Responding to SECs Proposed Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers With Less Than $150 Million in Assets Under Management, and Foreign Private Advisers01.24.11


MFA submitted a comment letter to the SEC in response to the SECs proposal Exemptions for Advisers to Venture Capital […]

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Topics: 1983 SEC No-Act. LEXIS 2576 26 S.E.C. 426, ABA Subcommittee on Private Investment Entities, affiliate letters, affiliated entities, Affiliated Person, AMRO Bank N.V., assets under management, Associated Persons, CFTC, Commodity Futures Trading Commission, commodity trading advisor, commodity trading advisors, Compliance and Management Structures, Control, CTA, de minimis exemption, Domestic, Equity Security, Exemptions, Exemptions Release, Factual Representations, Fair Value, Foreign Advisers and Subadvisers, foreign private advisers, Form ADV, Full Regulatory Access, general partner, Gross Assets Calculation, Hedge Fund Adviser Registration Rules, Independent Verification of Assets Requirement, Instrument, Investment Adviser Industry, investor, Kleinwort Benson Investment Management Limited, Limited Liability Company, Limited Partner, limited partnership, Master-Feeder Structure, Mercury Asset Management Plc., Multi-Jurisdicational Advisory Firms, no-action letters, Nominal Capital Account, Non-Control, Non-Registered Adviser, Non-U.S. Activities, Non-U.S. Investment Advisory Firms, Non-U.S. Law, Outstanding Voting Securities, oversight, Participating Affiliate, Peavey Commodity Futures Fund, pooled investment vehicle, private fund, Private Fund Advisers, Private Fund Registration, prudential regulators, Question VI.11, Record Owner, Redemption, Registered and Non-Registered Entities, Regulatory Assets, regulatory assets under management, Regulatory Authority, Royal Bank of Canada, SEC, SEC No-Action Letter, Secretary of the Treasury, Securities and Exchange Commission, Securities-Related Advice, Security-Based Swap, separate account structure, Side-by-Side Structure, Single Investor Private Funds, Specialized Expertise, Specialized Feeder, Staff Responses to Questions About the Custody Rule, Statutory Exemption, Subadvisers, Subsidiary Advisers, systemic risk, Tonopah Mining Co. of Nevada, total return swap, Transparency Rights, U.S. law, Unio de Banco de Brasileiros S.A., valuation methodology, venture capital funds, Voting Rights,

MFA Comments to the U.K. Hedge Fund Working Group’s Consultation Paper12.14.07


Today, MFA submitted the following response letter to the U.K. Hedge Fund Working Group on its Consultation Paper. The overall […]

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Topics: AIMA Alternative Investment Management Association, AML, audited annual accounts, board of directors, board of trustees, Borrowed Stock, bright line test, Chartered Financial Analyst Institute, cherry picking, client confidentiality, collateral agreements, collateral calls/two way collateral posting, commercial terms, compliance, compliance procedures, Comply or Explain, conflicts of interest, consultation paper, counterparties, counterparty risk, cross-market particpant working group, Derivative posistions, Difficult-to-Value Assets, Disclosure, disclosure thresholds, exchange traded posistions, exposure, Fair Value, Federal Reserve Bank of New York for OTC equity derivatives, fire sale, fund governing bodies, Fund Governing Body, funds of funds, global alternative investment industry, Global Investment Performance Standards, global relevance, Governance of Operational Risk, Hedge Fund Working Group, hedge funds, HFWG, illiquid securities, independent in-house functions, independent third parties, independent valuation services providers, inside information, Insider Dealing, Investment Policy, investor groups, investors, Irish Stock Exchange, jurisdictional requirements, Key man risk, Key Performance indicators (KPis) Fund Governance Disclosure, legal risks, Lenders/Prime Brokers/Dealers, Luxembourg Stock Exchange, managed futures funds, managers, Market Abuse, market price, market risk, marketable securities, Model Risk, net asset value, netting agreements, non-marketable, non-U.S. exchanges, offshore, one-stop shop, OTC derivatives transactions, OTC electronic transaction posistions, OTC market particpants, Outsourcing Risk, performance fee, Performance Measurement Disclosure, portfolio, portfolio management, potential conflicts, potential liability, President's Working Group on Private Pools of Capital (PWG), price sources, prime brokers, proxy voting policy, reconciliation errors, Regulators, regulatory implicationsm Websites, regulatory risks, Risk Disclosure, scenario analyses, Securities and Exchange Commission (SEC), segregation, service legal agreement, side letters, side pocket, soft limits, Sound Practices for Hedge Fund Managers, spectrum, stock lender, stress testing, third parties, Third Party Administrators, trade association, U.S. based funds, U.S. securities law, UK, uncertainity, United Kingdom, valuation, valuation determinations,

MFA Comments to IOSCO on Consultation Report on Principles for the Valuation of Hedge Fund Portfolios06.21.07


MFA submits comment letter to IOSCO on its Consultation Report on Principles for the Valuation of Hedge Fund Portfolios.

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Topics: absolute return strategies advisory, advocate, anti-money laundering, business continuity, Business Continutiy and Disaster Recovery, CFTC, Checklist for Code of Ethics, Checklist for Compliance Manuals, Commodity Futures Trading Commision, conflicts of interest, Congress, consistency, data vendors, Department of the Treasury, derivative market practices, disaster recovery, Fair Value, Federal Reserve, financial instruments, financial statement close process, FSA, global alternative investment industry, global capital markets, global set of principles, governing body, government bodies, hedge fund management, hedge fund managers, hedge funds, independence, India, Instrument, internal trading controls, investment portfolio, Investment Portfolios, Investor Protection, investors, IOSCO, IOSCO Report, IOSCO's 2007 32nd Annual Conference, key market soundness, macro-level guidance, major dealers, Management and Internal Trading Controls, market prices, material obstacles, MFA's 2005 Sound Practices, mission-critical, Mumbai., NAV, net asset value, operational framework, organized exchanges, portfolio strategies, President's Working Group on Financial Markets, price validation, pricing poliies and sources, private sector, public, PWG, Regulatory Controls, Responsibilites to Investors, risk management, risk monitoring, SEC, Securities and Exchange Committee, Securities Exchange Board of India, state agencies, third parties, Third Party Service Providers, Transactional Practices, transparency, U.S. regulatory Filings, United Kingdom's Financial Services Authority, United States, valuation, valuation of investments, Valuation Policies and Procedures,

MFA Submits Comments to IOSCO on Consultation Report on Hedge Funds Offered to Retail Investors05.31.06


MFA Submits Comments to IOSCO’s “Regulatory Environment for Hedge Funds” survey

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Topics: absolute return strategies accredited investors, alternative investment industry, assets under management, AUM, CFTC, client, Code of Ethics, Commodity Futures Trading Commission, commodity pool operator, commodity trading advisor, conflict of interest, Consultation Report on Hedge Funds Offered to Retail Investors, CPO, credit derivatives, CTA, dealers, Department of the Treasury, derivatives, due diligence, Fair Value, Federal Reserve System, Federal Securities Laws, fraudulent behavior, FTSE-250, fund of funds, futures, futures exchange, hard-to-v, hedge fund industry, hedge fund managers, hedge funds, illiquid investments, implications of the growth of hedge funds, institutional investors, International Organization of Securities Commissions, investment advisers, investment company, investor, IOSCO, IOSCO Technical Committe Standing Committee on Investment Management, Look Through, managed futures funds, MFA's 2005 Sound Practices, MFA's Sound Practices for Hedge Fund Managers, National Futures Association, NAV, net asset value, NFA, options contracts, pooled investment vehicle, pricing, private equity, private fund, real estate funds, registered investment companies, registered public offerings, regulation, Regulation D, reporting requirements, RICs, S&P 500, SC5 2003 Report, SEC, Securities and Exchange Commission, Senate Banking Subcommittee on Securities, side pocket, single-manager hedge funds, sophisticated investors, The Regulatory Environment for Hedge Funds, United States Congress, valuation, venture capital,

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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