MFA Comment Letters

Topic: general partner

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: aggregation AIMA, alpha swap, alternative investment funds, Alternative Investment Management Association, alternative investment strategies, anonymity, Asset Management Group of the Securities Industry and Financial Markets Association, assets under management, AUM, Bankruptcy Code, benchmark contracts, bespoke swaps, beta swap, board of directors, British Virgin Islands Financial Services Commission, burdensome, buy-side, cash-settled contracts, Cayman Islands, Cayman Islands Monetary Authority, CCP, central clearing, central counterparties, CFTC, chilling effect, cleared swaps, collateral, Committee of Payment and Settlement Systems, Commodity Futures Trading Commission, commodity interests, Commodity Markets Council, commodity pool, commodity pool operators, commodity trading advisors, compliance, corporations, CPO, CPO delegation, Cross-Border, CTA, custody rules, customer collateral, customer protection, DCM, DCO, Dealer, dealer-to-customer platforms, derivatives clearing organization, designated contract markets, Division of Market Oversight, Division of Swap Dealer and Intermediary Oversight, Dodd-Frank Act, due diligence, EFRPs, EMIR, EU, European Commission, European Union, exchange for related position, execution, exemptive relief, FCM, FCM counterparty, Financial Conduct Authority, financial counterparty, Financial Stability Board, floor brokers, Form CPO-PQR, Form CTA-PR, Form PF, Form PQR, FSB, Full Physical Segregation, fund of funds, futures commission merchant, GAAP, gamma swap, general partner, generally accepted accounting principles, gold, haircuts, harmonization, hedge fund, hedgers, Hong Kong, illiquid assets, initial margin, insolvency, inter-dealer market, interest rate markets, International Organization of Securities Commissions, International Swaps and Derivatives Association, introducing broker, invoice spreads, IOSCO, ISDA, J. Christopher Giancarlo, JOBS Act, legal segregation with operation commingling, limited liability companies, limited partnership, liquidity, loss allocation, LSOC, made available for trading, Major Swap Participant, mandatory clearing, Mark Wetjen, market infrastructures, market participant, master agreement, MAT, MF Global Inc., MSPs, National Futures Association, natural gas, NFA, no-action relief, Obama Administration, OTC derivatives, OTC Derivatives Regulators Group, owned entities, package transactions, passive ownership, Peregrine Financial Group, physically settled, Policy Makers, position limits, President Obama, price discovery, private equity fund, private funds, private investment funds, private investment vehicles, privately offered commodity pools, proprietary trading tools, public investment fund, quarterly account statements, real estate investment trust, recordkeeping requirements, registered investment adviser, regulation, regulatory framework, regulatory requirements, risk management, Scott O'Malia, SDR, SEC, Securities and Exchange Commission, Securities and Futures Commission, SEF, segregated account, service providers, Sharon Bowen, short, SIFMA AMG, silver, speculation, spot-month position limits, straight-through processing, swap butterflies, swap curves, swap data reporting, swap data repository, swap dealer, swap execution facilities, swaps, swaptions, systemic risk, temporary interim relief, third country, Timothy Massad, trading privileges, transparency, Trust, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, U.S. Congress, U.S. Department of the Treasury, U.S. person, United States, variation margin, Vincent A. McGonagle,

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,

Comment Letter to the Department of Labor in Response to the Departments Proposed Rule to Amend the Definition of Fiduciary Under ERISA02.03.11


MFA submitted a comment letter to the Department of Labor in response to the Departments proposed rule to amend the […]

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Topics: "may be considered" advice adverse, alternative investment vehicles, appraisal of property, appraisals, appraisers, asset-based fee compensation, bilateral agreement, California Public Employees' Retirement System, CFTC, Commodity Futures and Exchange Commission, Congress, custodians, daily mark, default, Department of Labor, derivative markets, diversification, DOL, DOL regulations, due diligence, Employee Benefits Security Administration, equity markets, equity securities, ERISA, ERISA fiduciaries, excise taxes, exemption applications, fee structure, fiduciary, fiduciary liability insurance. prime brokerage, fixed income markets, fund administration agreements, futures, general partner, general partners, good faith estimate, government safety new, hard-to-value, hedge fund manager, hedge fund managers, hedge funds, high water marks, impartial investment advice, inadvertent fiduciary status, Insurance and Investment, Internal Revenue Code, investment advisers, Investor Protection, Joseph Dear, managing member, market color, market concern, marketing services, may be considered standard, mutual understanding, net asset value, non-plan asset funds, options, overdraft coverage, pension fund, performance fee, plan asset vehicles, plan assets, pooled investment fund, pooled investment funds, pooled investment vehicles, pooled vehicle, pricing services, prime brokers, principal underwriter, private equity holdings, private investment fund, private pension, prohibited transaction provisions, purchaser, rate of return, real estate holdings, risk appetites, risk management, risk-adjusted returns, SEC, Securities and Exchange Commission, seller, selling exception, Senate Banking Subcommittee on Securities, settlement accommodations, short sales, side-pocket investments, significantly influence standard, structured products, swap counterparty, tailored advice, total returns, transaction reversal, valuation firm, valuation of assets,

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 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 on Custody of Funds or Securities of Clients by Investment Advisers07.28.09


MFA submitted a letter to the Securities and Exchange Commission today in response to its proposed amendments to its custody […]

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,
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