liability Archives - Managed Funds Association

MFA Submits Letter to CFTC on SEF Onboarding Documentation Issues01.08.14

On January 8, MFA submitted a letter as a request for action by the CFTC to conduct targeted compliance reviews […]

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Topics: CFTC Commodity Futures Trading Commission, SEF, Swap Execution Facility, swaps, competition, transparency, buy-side, made available for trading, MAT, Division of Clearing and Risk, Division of Market Oversight, Division of Swap Dealer and Intermediary Oversight, compliance, credit default swaps, CDS, straight-through processing, Javelin, trueEX, TW SEF LLC, clearing, risk management, no-action relief, futures commission merchant, FCM, request for quote, RFQ, block trades, market participants, breakage, bunched orders, derivatives clearing organization, DCO, interest rate swaps, liability, hedge fund investors, investment manager, OTC derivatives, over-the-counter derivatives,

MFA Submits Letter to CFTC on Proposed Wash Trade Advisory08.14.13

MFA submitted a comment letter to the CFTC in response to comments on the CME Group’s proposed Market Regulation Advisory […]

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Topics: CFTC Commodity Futures Trading Commission, CME Group, CME Group Inc., wash trade, Chicago mercantile exchange, The Board of Trade of the City of Chicago Inc., The New York Mercantile Exchange Inc., Commodity Exchange Inc., Kansas City Board of Trade, Globex, self-match prevention, inadvertent self-matches, marketplace, execution, market participants, chilling effect, liability, market risk, In re Goldwurm, Reddy v. CFTC, liquidity, algorithms, independent trading algorithms, market conditions, independent decision maker, automated trading system, decrementing, spreads,

MFA Letter to Bank of England Regarding Systemic and industry risk inherent in the currently proposed approach to the Administration of Lehman Brothers International (Europe)10.13.08

MFA sent a letter to the Governor of the Bank of England stating that MFA and its members are extremely […]

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Topics: Managed Funds Association alternative investment, hedge funds, fund of funds, managed futures funds, pensions funds, foundations, endowments, government entities, Alternative Investment Management Association in the UK, prime brokerage, Market Confidence, liability, liquidity, fund redemption, NAV calculations, collateral securities, systemic risk, James W. Giddens, Securities Investor Protection Corporation Trustee, Lehman Brothers Inc., LBI, United Kingdom Financial Services Authority, FSA, asset creditor, administrator liability, Bank of England, HM Treasury, UK Government, Department of the Treasury, Securities and Exchange Commission, SEC, CFTC, Commodity Futures Trading Commission,

MFA Comments to SEC on FINRA Regulation of Compensation, Fees and Expenses in Public Offerings of Real Estate Investment Trusts and Direct Participation Programs06.04.08

MFA submitted a comment letter to the SEC on FINRA’s rule 2810 with respect to trail commissions along with the […]

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Topics: Securities and Exchange Commission SEC, Financial Industry Regulatory Authority, FINRA, federal register, underwriting compensation, Commodity Pools, futures commission merchants, brokers, futures execution, broker-dealer, National Association of Securities Dealers, NASD, commodity, Commodity Futures Trading Commission, CFTC, Direct Participation Programs, DPPs, futures brokerage trail commission, trail commission, underwriter, R.J. O'Brien Fund Management LLC, R.J. O'Brien, introducing brokers, IBs, National Futures Association, NFA, CPOs, futures trading advisers, mutual fund, exchange-traded funds, ETF, exchange-traded notes, Motor Vehicle Manufacturers v. State Farm, diversify, exposure, price discovery, risk transference, Treasury bills, liability, transparency, net asset valuation, redemption rights, regulatory oversight, registration requirements, disclosure requirements, suitability standards, solicitation restriction, blue sky regulators, diversification, prospectus supplement, investor suitability requirement, North American Securities Administrators Association Guidelines for Registration of Commodity Pool Programs, NASAA, short-term capital gain, short-term capital loss,

MFA Comments to SEC on Proposed Naked Short Selling Antifraud Rule05.21.08

MFA submitted a comment letter to the SEC on the proposed naked short selling antifraud rule.

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Topics: Securities and Exchange Commission SEC, short selling, naked short selling, antifraud, market manipulation, capital markets, investor confidence, liquidity, market efficiency, Fraud, risk, portfolio, SEC Roundtable on the Regulation SHO Pilot, pump-and-dump scheme, execution, recklessness standard, liability, security lending standards, recordkeeping, prime brokerage arrangement, prime broker, locate requirement, direct market access systems, DMAS, electronic communications networks, ECN,

MFA Comments to SEC in Response to Proposed Amendments to Part 2 of Form ADV05.16.08

MFA filed a comment letter with the SEC, in response to the SEC’s proposed amendments to Part 2 of Form […]

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Topics: Securities and Exchange Commission SEC, Disclosure, Business Practices, conflict of interest, brochure, legal risk, Private Offering, private placement memorandum, liability, specialized advisory service, multi-strategy hedge fund, manager, SEC-registered adviser, state-registered adviser, adviser registration, Form ADV,

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: IOSCO FOHF Report, Investor Protection Issues, U.S. Funds of Hedge Funds, investment companies, Exemption, Disclosure, recordkeeping requirements, Commodity Pools, global alternative investment industry, hedge funds, managed futures funds, policymakers, absolute return strategies, private sector initiatives, hedge fund industry, United States, public sector, Federal Reserve, state agencies, Congress, private sector, major dealers, derivative market practices, international advisory and government bodies, United Kingdom's Financial Services Authority, Securities Exchange Board of India, retail investors, Full Part 4 Funds, Full Part 4 CPOs, Company Act FOHFs, IOSCO Technical Committe Standing Committee on Investment Management, retail investors' increased investment in FOHF's, IOSCO Report, Retail investment, retail market, regulatory regime, offering disclosure regime, advertising rules, Investor Protection, disclosure requirements, senior securities, management agreements, transactions, broker dealers, Financial Industry Regulatroy Authority, NASD, New York Stock Exchange, Investor Suitability, Manner of Offering, accredited investors, securities, private offering exemption, safe harbor, Public Offering, offering, mass mailings, General Solicitation, advertisement, open-end investment companies, mutual, liquidity, shareholders, periodic tender offers, high net worth requirements, qualified clients, natural person, adviser, net worth, initial investment requirements, retail funds, disclosure documents, compliance, compliance examinations, Company Act Registration, investment company, board members, interested persons, counsel, annual self-assessment, executive session, assets, bank, custody, broker-dealer, bank custodians, chief compliance officer, compliance policies and procedures, Federal Securities Laws, codes of ethics, fraudulent or manipulative practices, personal securities transactions, principal transactions, underlying fraud, outstanding voting, Affiliated Person, non-voting interests, agency transactions, asset coverage, company obligations, shares, dividends, borrowings, derivative instruments, advisory contracts, diversification, real estate, shareholder approval, breaches of fiduciary duty, compensation, registration statements, Form N-SAR, principal executive, principal financial officers, material fact, record keeping requirements, for cause examinations, sweep examinations, adviser operations, Subscription Agreement, verbatim risk of loss disclosure statements, table of contents, business background, risk factors, volatility, leverage, counterparty creditworthiness, commodities, margin obligations, fees, expenses, break-even chart, conflicts of interest, soft dollar, directed brokerage arrangements, futures brokers, tansferability and redemption rights, tax, liability, investor's capital contribution, undistributed profits, financial reporting to investors, Annual Report, Plain English Requirements, NFA Notice I-07-25, state securities regulators, statement of additional information, Company Act Disclosure Requirements, closed-end investment companies, Form N-2, prospectus, fee table, sales loads, offering price, dividend reinvestment, cash purchase plan fees, transaction fees, net assets, common shares, management fees, interest payments, borrowed funds, acquired fund fees, total annual expenses, initial investment, a 5% annual return, rask factors, public trading market, portfolio managers, Plain English Principles, glossaries, technical terms, administrators, custodians, affiliated broker, tax consequences, net asset value, capital stock, voting, liquidation, material pending legal proceedings, committee structure, ownership of shares, family of investment companies, proxy voting, independent registered public accounting firm, performance fees, securities transactions, tax status, offering prive, underwriters, legends, high risk, annual financial statements, independent public accountant, periodic statements, U.S. generally acceped accounting principles, accrual method of accounting, an oath or affirmation, unaudited semi-annual reports, fiscal period, Portfolio Holdings, advisory contract, Form N-CSR, Senior officer code of ethics, audit committee financial expert, audit, audit-related, share repurchases, U.S. GAAP, total return, futures professionals, promotional material, prospective investors, cherry picking, IOSCO Technical Committee, Securities and Exchange Commission, SEC, CFTC, Commodity Futures Trading Commission, commodity pool operator, CPO, fund of funds, Department of the Treasury, MFA's Sound Practices for Hedge Fund Managers, National Futures Association, NFA, FINRA,

MFA Comments to SEC on Concept Release Concerning Management’s Reports on Internal Controls09.18.06

MFA submits to the SEC comments on its concept release concerning management’s reports on internal controls.

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Topics: Securities and Exchange Commission SEC, financial reporting obligations, commodity pool, hedge funds, fund of funds, alternative investment vehicles, commodity pool operator, CPO, commodity trading advisor, CTA, smaller public companies, public commodity pools, prospective rule, Commodity Futures Trading Commission, CFTC, National Futures Association, NFA, registered investment companies, RICs, net asset value, NAV, Federal Securities Laws, self-regulatory organization, SRO, financial statements, Certified Public Accountant, futures commission merchants, FCM, Broker, registration statement, Form S-1, Form 10, blue sky laws, North American Securities Administrators Association, NASAA, regulatory audit, subsidiary ledger, securities, general ledger, asset, liability, capital, income, expense, statement of financial condition, advertising materials, commodity, price, Arizona, California, Massachusetts, Ohio, Texas, Oklahoma, Alabama, Iowa, Alaska, Pennsylvania, New Jersey, Minnesota, Committee of Sponsoring Organizations of the Treadway Commission, directors, limited liability companies, cost-benefit analysis, liquid assets, mark-to-market, banks, securities dealers, Auditing Standard No. 2, compliance requirements, rate of return, Public Company Accounting Oversight Board, AS2, efficiency, competition, capital formation, Peter Wallison,

MFA Comment Letters

Topic: liability