MFA Comment Letters

Topic: high water marks

Letter to ERISA Advisory Council on Hedge Funds’ Benefit to Pensions and Beneficiaries11.01.11


MFA submitted a written statement to the ERISA Advisory Council in connection with an Advisory Council meeting on November 8 […]

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 the Financial Stability Oversight Council’s Advance Notice and Request for Comment on the Criteria for Designating a Nonbank Financial Company as Systemically Important.11.05.10


MFA submitted a comment letter to the Financial Stability Oversight Council in response to the Councils advance notice and request […]

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Topics: "too big to fail alignment of interests, asset mix, assets under management, bank holding companies, banks, Board of Governors, BofA Merrill Lynch, Borrowing, broker-dealer, capital markets, CFTC, Cleared Transaction, collateral, Collateral Posting, Colombia University, Common Adviser, Congress, counterparties, counterparty risk management, Counterparty Risk Management Policy Group, credit exposure, Debt Guarantees, diversified portfolio, due diligence, Equity Capital Stability, FDIC, FDIC deposit insurance, Fed Chairman Bernanke, Federal Financial Institutions Examination Council, Federal Reserve System, Federal Reserve's Discount Window, Financial Assets, financial institutions, Financial Market Participants, Financial Stability Oversight Council, financial system, FSOC, gates, global mutual fund industry, Government-Funded Capital, Government-Issed Charter, hedge fund industry, hedge funds, high water marks, Highly Illiquid Assets, Inadequate Counterparty Risk, insurance companies, Investment Company Institute, investment portfolio, Legally Distinct Funds, leverage, leverage ratio, Liquidity Restrictions, Long Term Capital Managment, LTCM, major swap participants, margin requirements, market participants, Nonbank Financial Company, off-balance sheet exposures, OTC, OTC Derivatives Trades, over-the-counter derivatives, overnight borrowing, performance fees, Periods of Redemption, Position Size, prime brokerage, Redemptions, regulatory regime, retail investors, risk monitoring, risk-adjusted returns, SEC, Securities Exchange Commission, Short-Term Funding, Side Pocket Vehicles, sophisticated investors, Standardized Transactions, Structure of the Industry, swap dealers, systemic risk, Systemic Risk Monitoring, Systemically Important Financial Companies, Systemically Important Institutions, Systemically Relevant Firms, TARP, Troubled Asset Relief Program, U.S. Banking Industry, U.S. Financial Stability, ultra-high net worth individuals, Uncleared Transaction,
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