MFA Comment Letters

Topic: performance fee

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,

Letter to ERISA Advisory Council on Hedge Funds’ Benefit to Pensions and Beneficiaries11.01.11


MFA submitted a written statement to the ERISA Advisory Council in connection with an Advisory Council meeting on November 8 […]

Comment Letter to the Department of Labor in Response to the Departments Proposed Rule to Amend the Definition of Fiduciary Under ERISA02.03.11


MFA submitted a comment letter to the Department of Labor in response to the Departments proposed rule to amend the […]

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Topics: "may be considered" advice adverse, alternative investment vehicles, appraisal of property, appraisals, appraisers, asset-based fee compensation, bilateral agreement, California Public Employees' Retirement System, CFTC, Commodity Futures and Exchange Commission, Congress, custodians, daily mark, default, Department of Labor, derivative markets, diversification, DOL, DOL regulations, due diligence, Employee Benefits Security Administration, equity markets, equity securities, ERISA, ERISA fiduciaries, excise taxes, exemption applications, fee structure, fiduciary, fiduciary liability insurance. prime brokerage, fixed income markets, fund administration agreements, futures, general partner, general partners, good faith estimate, government safety new, hard-to-value, hedge fund manager, hedge fund managers, hedge funds, high water marks, impartial investment advice, inadvertent fiduciary status, Insurance and Investment, Internal Revenue Code, investment advisers, Investor Protection, Joseph Dear, managing member, market color, market concern, marketing services, may be considered standard, mutual understanding, net asset value, non-plan asset funds, options, overdraft coverage, pension fund, performance fee, plan asset vehicles, plan assets, pooled investment fund, pooled investment funds, pooled investment vehicles, pooled vehicle, pricing services, prime brokers, principal underwriter, private equity holdings, private investment fund, private pension, prohibited transaction provisions, purchaser, rate of return, real estate holdings, risk appetites, risk management, risk-adjusted returns, SEC, Securities and Exchange Commission, seller, selling exception, Senate Banking Subcommittee on Securities, settlement accommodations, short sales, side-pocket investments, significantly influence standard, structured products, swap counterparty, tailored advice, total returns, transaction reversal, valuation firm, valuation of assets,

Comment Letter Responding to SEC’s Proposal to Implement Amendments to the Advisers Act Contained in Title IV of the Dodd-Frank Act01.24.11


MFA submitted a comment letter todayto the SEC on its proposal to implement amendments to the Advisers Act contained in […]

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Topics: $1 Billion 11 and 12, 13 and 29, 15, 17, 5.D and 5.F, assets, assets under management, Bank of America-Merrill Lynch, banks, Basel Committee on Banking Supervision, beneficial owners, broker dealers, collateral, Columbia University, Commission on Form ADV, Committee on Financial Services, Compensation Structure, Compliance Risks, counterparties, Credit Unions, De Minimis Amount, Debt-to-Equity, Definition, Depository Institutions, Difficult-to-Value Assets, Duplicative Filing, effective date, Effective Date of Title IV, equity owner, European Central Bank, Excessive Compensation, Exemption, Fair Valu Hierarchy, Fair Value Methodology, Family Accounts, Form ADV, Form ADV Part 1A, Form ADV-T, FSA, GAAP, generally accepted accounting principles, Grandfathering Provisions, gross assets, Hearing on Industry Perspectives on the Obama Administration's Financial Regulatory Reform Proposals, hedge fund industry, Hedge Fund Manager Registration Rul, hedge fund managers, hedge funds, IARD, IARD System, Incentive-Based, Incentive-Based Compensation Arrangements, Income Thresholds, Instruction 5.b., Instruction 5.b(4), International Accounting Standards, investment adviser, Investment Adviser Registration Depository, Investment Management, Investor Protection Benefits, leverage, Leverage Ratios, Mid-Sized Manager, Mid-Sized Managers, National Securities Exchanges, net assets, NSMIA, Part 1A, performance fee, pooled investment vehicle, Portfolios, private adviser exemption, Private Fund Information, private fund managers, Proposed Instruction 1.b., Proposed Items 14, Proposed Items 5.A, Proprietary Accounts, Proprietary Accounts of the Manager, proprietary information, public disclosure, qualified client standard, qualified purchaser, registration, Registration Process, registration requirements, regulatory assets under management, Richard H. Baker, Schedule D, SEC, SEC-registered investment advisers, SEC-Registered Managers, SEC's Contract, Section 7.B.1, Securities and Exchange Commission, Securities Commissioner, state securities commission, Substantive Provision, systemic risk, Taxpayer Money, The Turner Review, threshold, Threshold of $25 Million, Tier 1 Financial Holding Company, transitional relief, U.S. House of Representatives, Unit-Linked Life Insurance, Unregistered Managers, Valuation Information, valuation methodology, venture capital funds, Wealth and Income Requirements,

MFA Comments to the U.K. Hedge Fund Working Group’s Consultation Paper12.14.07


Today, MFA submitted the following response letter to the U.K. Hedge Fund Working Group on its Consultation Paper. The overall […]

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Topics: AIMA Alternative Investment Management Association, AML, audited annual accounts, board of directors, board of trustees, Borrowed Stock, bright line test, Chartered Financial Analyst Institute, cherry picking, client confidentiality, collateral agreements, collateral calls/two way collateral posting, commercial terms, compliance, compliance procedures, Comply or Explain, conflicts of interest, consultation paper, counterparties, counterparty risk, cross-market particpant working group, Derivative posistions, Difficult-to-Value Assets, Disclosure, disclosure thresholds, exchange traded posistions, exposure, Fair Value, Federal Reserve Bank of New York for OTC equity derivatives, fire sale, fund governing bodies, Fund Governing Body, funds of funds, global alternative investment industry, Global Investment Performance Standards, global relevance, Governance of Operational Risk, Hedge Fund Working Group, hedge funds, HFWG, illiquid securities, independent in-house functions, independent third parties, independent valuation services providers, inside information, Insider Dealing, Investment Policy, investor groups, investors, Irish Stock Exchange, jurisdictional requirements, Key man risk, Key Performance indicators (KPis) Fund Governance Disclosure, legal risks, Lenders/Prime Brokers/Dealers, Luxembourg Stock Exchange, managed futures funds, managers, Market Abuse, market price, market risk, marketable securities, Model Risk, net asset value, netting agreements, non-marketable, non-U.S. exchanges, offshore, one-stop shop, OTC derivatives transactions, OTC electronic transaction posistions, OTC market particpants, Outsourcing Risk, performance fee, Performance Measurement Disclosure, portfolio, portfolio management, potential conflicts, potential liability, President's Working Group on Private Pools of Capital (PWG), price sources, prime brokers, proxy voting policy, reconciliation errors, Regulators, regulatory implicationsm Websites, regulatory risks, Risk Disclosure, scenario analyses, Securities and Exchange Commission (SEC), segregation, service legal agreement, side letters, side pocket, soft limits, Sound Practices for Hedge Fund Managers, spectrum, stock lender, stress testing, third parties, Third Party Administrators, trade association, U.S. based funds, U.S. securities law, UK, uncertainity, United Kingdom, valuation, valuation determinations,
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