MFA Comment Letters

Topic: Inadvertent Violation

Petition to SEC for Rulemaking on Rule 502 of Regulation D, Ban General Solicitation01.06.12


MFA submitted a comment letter to the SEC requesting that the Commission amend Rule 502(c) of Regulation D to eliminate […]

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Topics: accredited investors Administrative Costs, Anti-Fraud Provisions, Auditors, Ban on General Solicitation, Ban on General Solicitation and Advertising, Broadcast Over Television, Broker, Business Practices, capital formation, Chairman Schapiro, Competitiveness, Congressman Darrell Issa, Consulting Firm, Continuous Offerings, Disclosure, Division of Corporation Finance, Division of Investment Management, Economic Growth, Federal Securities Laws, Fraud, Fund Managers, General Advertising, General Solicitation, hedge funds, House Committee on Oversight and Government Reform, House of Representatives, Inadvertent Violation, Independent Regulatory Agencies, Industry Conferences, Inquiries, Interpretive Framework, investment company, Investor Criteria, Investor Protection, Investor Protections, Issuer, Job Creation, Legal Costs, Limited Partnerships, Offerings or Sales, Offers or Sales Securities, Over-the-Counter Derivatives Markets, oversight, Petition for Rulemaking, Policy Makers, Pre-Existing Relationship Doctrine, Pre-Existing Substantive Relationship, prime brokers, private funds, Private Funds Managers, Private Offering, Proprietary Investment Data, Protecting Investors: A Half Century of Investment Company Regulation, Public Offering, Qualified Potential Investors, qualified purchasers, Radio, Regulators, SEC, Securities and Exchange Commission, Selling Agent, Senate, sophisticated investors, Subscription Agreement, Systemic Risk Assessment, Third-Party, transparency, United States Congress, Unsophisticated Investors, Waiting Period, Wealth Tests,

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,
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