MFA Comment Letters

Topic: oversight

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,

Comment Letter on IOSCO’s Consultation Report on ‘Regulatory Issues Raised by the Impact of Technological Changes on Market Integrity and Efficiency,’08.12.11


MFA submitted comments to IOSCO on its consultation report on Regulatory Issues Raised by the Impact of Technological Changes on […]

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Topics: 1963 Special Study 1963 Special Study of the Securities Markets, 2010, affirmative stock locate framework, AIG, algorithmic trading, algorithms, Arndt, Barclays Capital Equity Research, Barclays Plc., bid-ask spreads, broker dealers, buy-side brokers, CFTC, circuit breakers, co-location services, computer programs, connectivity, Consultation Report, dark pools, DEA, Division of Risk, Dow Jones Industrial Average, E-Trade, Economic Growth, educational campaigns, effective spreads in European equities, efficiency, electronic markets, Elizabeth Murphy, empirical data, endowments, erroneous trades, ETFs, EU, executing brokers, execution speed, Fannie Mae, fees, Fidelity, fiduciary obligation, Financial Crisis of 2008, fixed commission rates, flash crash, Flash Crash of May 6, foundations, France, Freddie Mac, Germany, Goldman Sachs, Gomber, HFT, high frequency trading, institutional investor, institutional investors, insurance companies, intermediary firm, International Organization of Securities Commissions, investment time horizons, Japan, Joint Advisory Committee on Emerging Regulatory Issues, Joint Industry Limit Up-Limit Down Proposal, LaBranche, limit-up/limit-down systems, long-term, low latency, Lutat, market access, Market Break of 1962, Market Crash of 1987, market depth, market dislocations, market efficiencies, market information, market liquidity, market trends, Merrill Lynch, monopolies, Mr. Werner Bijkerk, mutual funds, Nasdaq, National Securities Clearing Corporation, NBBO, New York Stock Exchange, NSCC, Office of Markets in the Division of Risk, order execution, order-to-trade ratios, OSCO, oversight, passive, pensions, Peter Gomber, pricing reliability, proprietary, proprietary trading tools, quote stuffing, Regulatory Issues Raised by the Impact of Technological Change on Market Integrity and Efficiency, Rosenblatt Securities, Schwab, SEC, Securities Exchange Commission, single-stock circuit breakers, Spain, sponsored access, spreads, standardize disclosure, Strategy and Financial Innovation, Strategy and Innovation memorandum, TABB Group, TAGG Group, TD Ameritrade, Technical Committee, Technical Committee of the International Organization of Securities Commissions, technological developments, third party vendors, Thomson, threshold securities, trading strategies, transaction delivery, transaction fees, transparency, two-sided displayed quotes, Uhle, UK, wait-and-see, Washington Mutual,

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,

Comment Letter Regarding SEC Study on the Whether the Establishment of a Self-Regulatory Organization Would Improve the Frequency of Examinations of Investment Advisers12.16.10


MFA submitted a letter today providing comments to the SEC on Section 914 of the Dodd-Frank Act, which requires the […]

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Topics: assets under management broker dealers, broker-dealer, capital formation, CFTC, check-the-box, chief compliance officer, clearing, clearing agencies, Committee on Financial Services, Commodities Futures Trading Commission, compliance, Compliance Policies, counterparties, custody, Department of Labor, Department of the Treasury, derivative, derivatives trading activities, Disclosure, Dodd-Frank Act, fiduciary duty, Financial Industry Regulatory Authority, financial planners, Financial Stability Oversight Council, FINRA, forensic accounting, FSOC, hedge fund managers, initial margin, insider trading, investment activity, Investment Adviser Association and National Regulatory Services, investment adviser examination, investment advisory firm, Investor Protection, leverage, liquidation, major swap participants, msp, mutual fund, NASD, National Association of Securities Dealers, nregistered securities, Obama Administration's Financial Regulatory Reform Proposals, OCIE, Office of Compliance Inspections and Examinations, OTC derivatives, over-the-counter derivatives, over-the-counter securities markets, oversight, pension, private fund manager, purchase, registration, reporting, sale, SEC, Securities and Exchange Commission, securities lending, securities market, securities transactions, self-regulatory organization, short selling, small advisers, SRO, swap dealers, swaps, systemic risk, trading positions, traditional asset management firm, Transaction Reporting, transparency, U.S. House of Representatives, variation margin, wealth managers,

MFA’s Comments to IOSCO on the Consultation Report on Unregulated Financial Markets and Products06.15.09


MFA submitted a letter to the International Organization of Securities Commissions (IOSCO) in response to its Consultation Report on Unregulated […]

MFA Files Joint Comment Letter to California Department of Corporations on Proposed Rule Requiring Hedge Fund Managers to Register with the State11.21.07


MFA and the Coalition of Private Investment Companies submit a joint comment letter to the California Department of Corporations on […]

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Topics: 2003 staff report accredited investor standard, accredited investors, Agreement Among PWG and U.S. Agency Principals on Principles and Guidelines Regarding Private Pools of Capital, assets under management, AUM, Board of Governors of the Federal Reserve System (FED), brokerage firms, California, California Corporate Securities Law, California Public Employees' Retirement System, CalPERS, capital calls, CFTC, chief investment officer, Coalition of Private Investment Companies, Commisioner of the California Department of Corporations, Commodity Futures Trading Commission, Congress, CPIC, Data, de minimis standard, Department of Corporations, Department of the Treasury, due diligence, electronic filing, Exempt Advisers, Exemption, fiduciary standards, financial market, financial products, Form D, Fraud, fund advisers, fund of funds, global alternative investment industry, hedge funds, implications of the growth of hedge funds, Industry Standards, industry trends, initial statement of reasons, investment adviser, investment advisers, Investor Protection, Investor's Committee of the Advisory Group, James Chanos, jobs, jurisdiction, liquidation restrictions, liscensing exemption, locked up, London, managed future funds, national markets, New York, office rents, oversight, Pension Funds, pooled investment vehicles, President's Working Group on Financial Markets, Private Offering, private offerings, privately-offered pooled investment vehicles, professional asset managers, proposal, public, PWG, qualified purchasers, Redemptions, registered investment companies, registrant, requirement, risk, San Francisco, SEC, Securities and Exchange Commission, Sound Practices for Hedge Fund Managers, spillover effect, start-up companies, state registration, support services, tax revenues, The Bureau of National Affairs, training personal, venture capital,
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