MFA Comment Letters

Topic: fees

MFA Submits Comments on AIFMD Remuneration09.27.12


MFA submitted comments to the European Securities and Markets Authority (ESMA) on its consultation on guidelines on sound remuneration policies […]

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Topics: affiliated group AIFM, AIFMD, alignment of interests, alternative instruments, Annual Report, assets under management, audit, AUM, Balance Sheet, bank, bonuses, capital requirements, carried interest, chief compliance officer, Claw-Back, commissions, compliance, compliance staff, Confidential Information, consultation paper, control function, control functions, Council of the European Union, counsel, credit institutions, deferral of remuneration and pension, deferred remuneration, delegate, deposit-taking entity, Disclosure, distributions, ESMA, EU, EU Passport, European Commission, European Parliament, European Securities and Markets Authority, European Union, excessive risk-taking, fee structure, fees, financial institutions, financial stability, governing body, government insurance, hedge fund managers, hedge funds, Identified Staff, institutional investor, Insurance, investors, junior partner, Limited Liability Company, limited liability partnership, LLC, LLP, management bodies, management committees, marketing, material risk, Member State, Member State competent authorities, MiFID, MiFID firms, minimum capital requirements, non-deferred remuneration, non-EU AIFM, non-executive directors, operational risk, other risk taker, own account dealer, owner-managed AIFM, parent company, pension, performance fee, performance measures, Policy Makers, private placement, private placement regime, proportionality principle, public shareholders, redemption rights, Regulators, RemCo, remuneration, remuneration policies, retention policy, risk alignment, risk management, risk profile, Senior Management, service providers, shareholders, sophisticated investors, stakeholders, tax, Tax Implications, third country, UCITS, underperformance, United Kingdom, variable remuneration,

Comment Letter on IOSCO’s Consultation Report on ‘Regulatory Issues Raised by the Impact of Technological Changes on Market Integrity and Efficiency,’08.12.11


MFA submitted comments to IOSCO on its consultation report on Regulatory Issues Raised by the Impact of Technological Changes on […]

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Topics: 1963 Special Study 1963 Special Study of the Securities Markets, 2010, affirmative stock locate framework, AIG, algorithmic trading, algorithms, Arndt, Barclays Capital Equity Research, Barclays Plc., bid-ask spreads, broker dealers, buy-side brokers, CFTC, circuit breakers, co-location services, computer programs, connectivity, Consultation Report, dark pools, DEA, Division of Risk, Dow Jones Industrial Average, E-Trade, Economic Growth, educational campaigns, effective spreads in European equities, efficiency, electronic markets, Elizabeth Murphy, empirical data, endowments, erroneous trades, ETFs, EU, executing brokers, execution speed, Fannie Mae, fees, Fidelity, fiduciary obligation, Financial Crisis of 2008, fixed commission rates, flash crash, Flash Crash of May 6, foundations, France, Freddie Mac, Germany, Goldman Sachs, Gomber, HFT, high frequency trading, institutional investor, institutional investors, insurance companies, intermediary firm, International Organization of Securities Commissions, investment time horizons, Japan, Joint Advisory Committee on Emerging Regulatory Issues, Joint Industry Limit Up-Limit Down Proposal, LaBranche, limit-up/limit-down systems, long-term, low latency, Lutat, market access, Market Break of 1962, Market Crash of 1987, market depth, market dislocations, market efficiencies, market information, market liquidity, market trends, Merrill Lynch, monopolies, Mr. Werner Bijkerk, mutual funds, Nasdaq, National Securities Clearing Corporation, NBBO, New York Stock Exchange, NSCC, Office of Markets in the Division of Risk, order execution, order-to-trade ratios, OSCO, oversight, passive, pensions, Peter Gomber, pricing reliability, proprietary, proprietary trading tools, quote stuffing, Regulatory Issues Raised by the Impact of Technological Change on Market Integrity and Efficiency, Rosenblatt Securities, Schwab, SEC, Securities Exchange Commission, single-stock circuit breakers, Spain, sponsored access, spreads, standardize disclosure, Strategy and Financial Innovation, Strategy and Innovation memorandum, TABB Group, TAGG Group, TD Ameritrade, Technical Committee, Technical Committee of the International Organization of Securities Commissions, technological developments, third party vendors, Thomson, threshold securities, trading strategies, transaction delivery, transaction fees, transparency, two-sided displayed quotes, Uhle, UK, wait-and-see, Washington Mutual,

Comment Letter to SEC Responding to Concept Release on Equity Market Structure05.07.10


MFA submitted a letter to the SEC in response to its request for comments on its Equity Market Structure Concept […]

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Topics: algorithm alternative trading systems, asset classes, automated trading, bid-ask spreads, broker dealers, buyers, cancellation rate, capital allocation, capital formation, co-location, competitive barriers, connectivity vendors, dark pools, decimalization, Designated Market Maker, direct market access, ECN, efficiency, electronic communication networks, electronic trading desks, electronically accessibel quotes, endowments, Equity Market Structure, execution speed, fees, fixed income, foundations, France, frontrunning, Germany, global financial crisis, hedging, HFT, high frequency trading, institutional investors, insurance companies, inter-market arbitrage, Intermarket Trading System Plan, inventory risks, investment time horizon, investor confidence, ITS, Japan, large cap stocks, limit orders, liquidity, long-term investors, low latency technology, market color, market consolidation, Market Crash of 1987, market depth, market fragmentation, market maker, momentum ignition, mutual fund, Nasdaq, National Association of Securities Dealers Inc., National Market System, New York Stock Exchange, non-public trading, NYSE, Office of Economic Analysis, order anticipation, order cancellations, order handling rules, order protection rule, pensions, phantom liquidity, pinging, post-trade execution, post-trade transparency, price discovery, price swings, private investment pools, proprietary trading, public information, quantitative strategies, quote flickering, registered investment advisers, regulation ATS, Regulation NMS, retail investors, risk management, SEC, sector change, Securities and Exchange Commission, securities lending, sellers, short selling, short-term traders, small cap stocks, specialist quotes, sponsored access, spreads, technology, trading desk, trading volume, transaction costs, transparency, Treasury ETF, trends, U.S Treasury bonds, U.S. Department of Justice, United Kingdom, upstairs market, volatility,

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,

MFA Letter to NASD Regarding Proposed Rule on Member Private Offerings07.20.07


MFA submits comments to the NASD regarding NASD Proposed Rule 2721, Member Private Offerings, requesting that privately offered commodity pools […]

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