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MFA Comment Letters

› Issues & Policy

Topic: management fees

Comment Letter on Incentive-Based Compensation Arrangements05.31.11


MFA submitted a comment letter to the SEC in response to the joint agency proposed rules that would prohibit incentive-based […]

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Topics: Incentive-Based Compensation Agreements Joint Agencies, systemic risks, covered financial institutions, Office of the Comptroller of the Currency, Treasury (OCC), Board of Governors of the Federal Reserve System, Federal Deposit Insurance Corporation (FDIC), Office of Thrift Supervision, Treasury (OTS), National Credit Union Administration, (NCUA), Federal Housing Finance Agency, financial stability, upside performance, hedge fund advisers, adviser employees, risk management, compensation arrangements, align the interests, portfolio management activities, alignment of interest, management fees, performance fees, high water marks, risk-adjusted returns, Financial Stability Oversight Council, systemically different, leverage, liquidity risk, maturity mismatch, regulatory scrutiny, asset management structures, investment managers, borrowing arrangements, derivatives contracts, redemption rights, equity base, redemption-forced liquidations, debt capital, prime brokers, lending parties, liquidations, tax, Internal Revenue Service, IRS, pooled investment vehicles, consolidated balance sheet, accounting principles, net assets, gross assets, deferred compensation, incentive compensation arrangements, inflation,

Comment Letter Responding to the Committee of European Banking Supervisors’ Consultation Paper on Remuneration Guidelines.11.08.10


MFA submitted a comment letter to the Committee of European Banking Supervisors in response to its consultation paper on remuneration […]

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Topics: Renumeration Policies and Practices Committee of European Banking Supvisors, CEBS, Consultation Paper 42, risk management, hedge fund advisers, Member State regulators, Neutralization, Identified Staff, Ex-Post Adjustments, Required Ratios, Variable and Fixed Remuneration, public disclosure, Transition Period, Financial Companies, U.K. Financial Services Authority, CRD, Asset Management, Depository Institutions, Privately-Owned Business, sophisticated investors, Large Financial Institutions, portfolio management activities, Public Shareholder, alignment of interest, Revenue Model, management fees, performance fees, Senior Employees of Hedge Fund Advisers, European Regulatory Regime, Claw-Back, financial institution, high water marks, risk-adjusted returns, Short-Term Risk Taking, Multi-Year Assessment, Remuneration Ratio, Public Disclosure Requirements, Senior Management, Hedge Fund Adviser Fees, Fixed Overhead, Variable Renumeration, capital requirements, financial stability, Disclosure Obligation, publicly traded securities, Non-EU Parent Companies, Tax Implications, tax liabilities, Publicly Traded Companies, valuation,

Comment Letter Responding to the UK Financial Services Authority’s Consultation Paperon Revising its Remuneration Code.10.08.10


MFA filed a comment letterwith the UKs Financial Services Authority, in response to the FSAs consultation paperon revising its remuneration […]

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Topics: Remuneration code Financial Services Authority, FSA, risk management, governance structure, hedge fund advisers, proportionality principle, hedge fund managers, Depository Institutions, government insurance, government assistance, banks, Large Financial Institutions, privately owned, public shareholders, portfolio management activities, alignment of interests, Revenue Model, management fees, performance fees, Claw-Back, high-water mark, remuneration ratio requirements, Code Staff, risk takers, deferral requirements, Publicly Traded Companies, variable compensation, fixed compensation,

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: Securities and Exchange Commission SEC, pay to play practices, government assets, political contributions, investment adviser, investment management services, government entities, third party placement agents, municipal securities, Municipal Securities Rulemaking Board, MSRB, investment management industry, municipal underwritings, municipal securities underwriters, municipal securities professional, chief compliance officer, American Bar Association, Committee on Federal Regulation of the American Bar Association, state and local entities, legal authorities, compliance burden, agency, authority, instrumentality of the State, plan, program, pool of assets, political action committee, inauguration or transition committee, local or state political party, Foundation, charitable institution, government official, Regulators, covered associates, general partner, executive officer, Broker, Dealer, municipal securities business, municipal securities representative, municipal securities principals, sales principals, principal business unit, look-back provision, look-back period, securities firms, academic institutions, chilling effect, soliciting, personal political activities, beneficial owners, family members of covered associates, portfolio manager, written compliance policies and procedures, pre-approval procedures, disproportionately severe punishment, private fund, limited partnership, redemption rights, public pension plans, interest, contractual rights and obligations, management fees, liquidity, fund assets, redemption requests, investment services, fiduciary duty, assets, compensation arrangements, institutional investor, incentive fee structure, backward-looking provisions, operational challenges, compliance procedures, pooled investment vehicle, de minimi exception, returned contribution, Inadvertent Violation, inadvertent contribution, covered investment pool, registered investment companies, publicly offered securities, fund of funds, direct investment, platform arrangement, direct investors, third party placement agent, pension, third party solicitors, placement agent, hedge fund managers, hedge funds, offshore managers, marketing activities, broker-dealer, requests for proposals, due diligence, investment advisory services, investment techniques, investment objectives, risk management, anti-competitive effects, California Public Employees' Retirement System, CalPERS, CalSTRS, Los Angeles County Employees' Retirement System, Los Angeles City Employees' Retirement System, New Mexico Educational Retirement Board, Teacher Retirement System of Texas, Pennsylvania Public School Employees' Retirement System, Pennsylvania State Employment Retirement System, Connecticut, Massachusetts, Oklahoma, Washington, New York State Common Retirement Fund, New York City Employees' Retirement System, New Mexico Investment Council, New York, Illinois, pay to play scandals, Disclosure, transparency, state and federal laws, regulations, registration, cash solicitation, Wall St. Journal, code of ethics rule, compliance costs, Form ADV, registered investment adviser, unregistered adviser, pre-approval policies, affiliated broker-dealer,

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,
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