MFA Comment Letters

Topic: pension

MFA Submits Letter to SEC on Proposed Capital, Margin, and Segregation Rules02.22.13


MFA submitted a comment letter to the Securities and Exchange Commission (SEC) on its proposed rules on “Capital, Margin, and […]

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Topics: "too big to fail \, 111th Congress, accounting, AIG, American International Group, asset class, asymmetrical initial margin exchange, asymmetry, bankruptcy, bankruptcy estate, Bart Chilton, Basel Committee on Banking Supervision, Ben Bernanke, best practices, bilateral exchange of variation margin, Broker, broker-dealer, buy-side firms, capital, capital charge, capital formation, capital inefficiency, capital requirements, Cash Flow, CCP, CDS, central clearing, central counterparty, CFTC, Chicago Mercantile Exchange Holdings Inc., Chicago Trading Company, collateral, collateral management, collateral management stystems, commodity broker, Commodity Futures Trading Commission, complexity, compliance, compliance date, Council of the European Union, counterparties, counterparty risk, credit default swap, credit risk, creditworthiness, cross-margining, cross-product master netting agreements, customer collateral, customer protection, customer replicability, customized risk management tools, Darrell Duffie, DCO, Dealer, dealers, default, default segregation model, derivatives, derivatives clearing organization, Division of Clearing and Intermediary Oversight, Dodd-Frank Act, efficiency, eligible collateral, endowments, enhanced protections, Eric Chern, European Commission, European Parliament, federal register, Federal Reserve Bank of New York, Federal Reserve Bank of New York Staff Report No. 424, Federal Reserve Board, fellow customer risk, financial contagion, financial crisis, Financial Industry Regulatory Authority, financial institutions, financial instrument, financial system, FINRA, forwards, Fraud, haircuts, hedge funds, House Committee on Financial Services, ICE Clear Europe Limited, ICI, independent third party custodian, Individual Segregation, initial margin, insolvency, international harmonization of regulations, International Organization of Securities Commissions, international regulatory standards, Investment Company Institute, investment risk, Investor Protection, IOSCO, ISDA, ISDA Margin Survey 2012, LCH.Clearnet Ltd., legal segregation with operation commingling, Lehman Brothers, leverage, liquidation, liquidation time horizon, liquidity, LSOC, Major Security-Based Swap Participant, Major Swap Participant, mandatory clearing, margin, margin requirements, margining, market participants, market practice, market risk, MF Global Inc., money market instruments, multiplier, netting, New York Portfolio Clearing LLC, non-commercial end-users, Notice of Exclusive Control, omnibus segregation, operational and legal commingling, operational costs, operational risk, Options Clearing Corporation, OTC derivatives, out-of-the-money, pension, Peregrine Financial Group, portability, portfolio compression, portfolio margining, portfolio reconciliation, Private Funds Managers, pro-cyclical effects, product type, proprietary information, prudential regulators, reconciliation, reform, registered clearing agencies, regulation, regulatory arbitrage, repurchase agreements, risk, risk management, Robert Wasserman, Russell Wasendorf, SEC, securities, Securities and Exchange Commission, Securities Industry and Financial Markets Association, Security-Based Swap Dealer, Security-Based Swap Transactions, security-based swaps, segregation, segregation model, sell-side firms, settlement, settlement risk, SIFMA, state and federal laws, state bank regulator, swap dealer, swap dealers, Swap Trading Relationship Documentation, systemic risk, tentative net capital, third-party custody arrangement, too interconnected to fail, trade repositories, trading costs, transparency, tri-party custodial arrangements, two-way margining, U.S. dollar, university endowment, Value at Risk, VaR, variation margin, White Paper, Working Group on Margining Requirements,

MFA and AIMA Submit Joint Letter to CFTC on Further Proposed Cross-Border Guidance02.06.13


MFA and AIMA jointly submitted a comment letter to the Commodity Futures Trading Commission (CFTC) on its “Further Proposed Guidance […]

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Topics: adviser registration AIMA, Alternative Investment Management Association, buy-side market participants, CCP, central clearing, central counterparty, CFTC, clearing, collective investment vehicles, commodities, Commodity Futures Trading Commission, commodity pool, commodity pool operator, Corporation, Council of the European Union, CPO, CPPSS-IOSCO, Cross-Border, de minimis, Dealer, derivatives, direct or indirect ownership, Dodd-Frank Act, duplicative regulation, ESMA, estate, EU, European Parliament, European Securities and Markets Authority, European Union, execution, foreign regulators, Form CPO-PQR, fund of funds, G20, G20 commitments, Gary Gensler, hedge fund managers, Hong Kong, Hong Kong Monetary Authority, income tax, international harmonization of regulations, International Organization of Securities Commissions, interpretive guidance, investment fund, investment manager, IOSCO, joint-stock company, Limited Liability Company, limited liability partnership, listed entity, LLC, LLP, Look Through, Major Swap Participant, majority ownership, mandatory clearing requirements, market participants, Mary Schapiro, MAS, Monetary Authority of Singapore, msp, OCC, Office of the Comptroller of the Currency, OTC derivatives, OTC derivatives market, OTC derivatives reform, over-the-counter derivatives, ownership test, partnership, pension, phase-in period, pooled accounts, prime brokers, principal place of business test, registration, regulatory framework, SEC, Securities and Exchange Commission, Singapore, swap dealer, swaps, systemic risk, trade repositories, transparency, Trust, U.S. person,

MFA Submits Comments on AIFMD Remuneration09.27.12


MFA submitted comments to the European Securities and Markets Authority (ESMA) on its consultation on guidelines on sound remuneration policies […]

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Topics: affiliated group AIFM, AIFMD, alignment of interests, alternative instruments, Annual Report, assets under management, audit, AUM, Balance Sheet, bank, bonuses, capital requirements, carried interest, chief compliance officer, Claw-Back, commissions, compliance, compliance staff, Confidential Information, consultation paper, control function, control functions, Council of the European Union, counsel, credit institutions, deferral of remuneration and pension, deferred remuneration, delegate, deposit-taking entity, Disclosure, distributions, ESMA, EU, EU Passport, European Commission, European Parliament, European Securities and Markets Authority, European Union, excessive risk-taking, fee structure, fees, financial institutions, financial stability, governing body, government insurance, hedge fund managers, hedge funds, Identified Staff, institutional investor, Insurance, investors, junior partner, Limited Liability Company, limited liability partnership, LLC, LLP, management bodies, management committees, marketing, material risk, Member State, Member State competent authorities, MiFID, MiFID firms, minimum capital requirements, non-deferred remuneration, non-EU AIFM, non-executive directors, operational risk, other risk taker, own account dealer, owner-managed AIFM, parent company, pension, performance fee, performance measures, Policy Makers, private placement, private placement regime, proportionality principle, public shareholders, redemption rights, Regulators, RemCo, remuneration, remuneration policies, retention policy, risk alignment, risk management, risk profile, Senior Management, service providers, shareholders, sophisticated investors, stakeholders, tax, Tax Implications, third country, UCITS, underperformance, United Kingdom, variable remuneration,

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,
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