MFA Comment Letters

Topic: Policy Makers

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: aggregation AIMA, alpha swap, alternative investment funds, Alternative Investment Management Association, alternative investment strategies, anonymity, Asset Management Group of the Securities Industry and Financial Markets Association, assets under management, AUM, Bankruptcy Code, benchmark contracts, bespoke swaps, beta swap, board of directors, British Virgin Islands Financial Services Commission, burdensome, buy-side, cash-settled contracts, Cayman Islands, Cayman Islands Monetary Authority, CCP, central clearing, central counterparties, CFTC, chilling effect, cleared swaps, collateral, Committee of Payment and Settlement Systems, Commodity Futures Trading Commission, commodity interests, Commodity Markets Council, commodity pool, commodity pool operators, commodity trading advisors, compliance, corporations, CPO, CPO delegation, Cross-Border, CTA, custody rules, customer collateral, customer protection, DCM, DCO, Dealer, dealer-to-customer platforms, derivatives clearing organization, designated contract markets, Division of Market Oversight, Division of Swap Dealer and Intermediary Oversight, Dodd-Frank Act, due diligence, EFRPs, EMIR, EU, European Commission, European Union, exchange for related position, execution, exemptive relief, FCM, FCM counterparty, Financial Conduct Authority, financial counterparty, Financial Stability Board, floor brokers, Form CPO-PQR, Form CTA-PR, Form PF, Form PQR, FSB, Full Physical Segregation, fund of funds, futures commission merchant, GAAP, gamma swap, general partner, generally accepted accounting principles, gold, haircuts, harmonization, hedge fund, hedgers, Hong Kong, illiquid assets, initial margin, insolvency, inter-dealer market, interest rate markets, International Organization of Securities Commissions, International Swaps and Derivatives Association, introducing broker, invoice spreads, IOSCO, ISDA, J. Christopher Giancarlo, JOBS Act, legal segregation with operation commingling, limited liability companies, limited partnership, liquidity, loss allocation, LSOC, made available for trading, Major Swap Participant, mandatory clearing, Mark Wetjen, market infrastructures, market participant, master agreement, MAT, MF Global Inc., MSPs, National Futures Association, natural gas, NFA, no-action relief, Obama Administration, OTC derivatives, OTC Derivatives Regulators Group, owned entities, package transactions, passive ownership, Peregrine Financial Group, physically settled, Policy Makers, position limits, President Obama, price discovery, private equity fund, private funds, private investment funds, private investment vehicles, privately offered commodity pools, proprietary trading tools, public investment fund, quarterly account statements, real estate investment trust, recordkeeping requirements, registered investment adviser, regulation, regulatory framework, regulatory requirements, risk management, Scott O'Malia, SDR, SEC, Securities and Exchange Commission, Securities and Futures Commission, SEF, segregated account, service providers, Sharon Bowen, short, SIFMA AMG, silver, speculation, spot-month position limits, straight-through processing, swap butterflies, swap curves, swap data reporting, swap data repository, swap dealer, swap execution facilities, swaps, swaptions, systemic risk, temporary interim relief, third country, Timothy Massad, trading privileges, transparency, Trust, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, U.S. Congress, U.S. Department of the Treasury, U.S. person, United States, variation margin, Vincent A. McGonagle,

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,

MFA and AIMA Submit Comments to CFTC on Cross-Border Guidance08.28.12


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

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Topics: accredited investors African Development Bank, AIMA, Alternative Investment Management Association, Asian Development Bank, banks, Business Conduct Standards, buy-side firms, CFTC, chief compliance officer, clearing, collective investment vehicles, comment letter, Commodity Futures Trading Commission, commodity pool, commodity pool operator, commodity swaps, compliance costs, Corporation, cost-benefit analysis, Council of the European Union, counterparties, CPO, CPO registration requirements, Dealer, dealers, Department of the Treasury, derivatives, derivatives markets, direct or indirect ownership, duplicative regulation, entity-level requirement, ESMA, estate, European Parliament, European Securities and Markets Authority, execution, fiduciary, financial crisis, financial stability, financial system, foreign banks, foreign entity, Form CPO-PQR, fund, fund of funds, G20, G20 commitments, general partnerships, hedge fund administrator, hedge fund industry, hedge fund managers, Hong Kong, Hong Kong Monetary Authority, income tax, Inter-American Development Bank, International Bank for Reconstruction and Development, international harmonization of regulations, International Monetary Fund, International Organization of Securities Commissions, interpretive guidance, IOSCO, Jill Sommers, joint-stock company, limited liability companies, listed entity, Look Through, major swap participants, majority ownership, margining, market impact, market participants, Monetary Authority of Singapore, MSPs, natural person, non-U.S. investment fund, non-U.S. market participants, non-U.S. persons, OTC derivatives, OTC derivatives market, over-the-counter derivatives, partnership, pension plans, Policy Makers, pooled accounts, portfolio reconciliation, prime brokers, qualified eligible person, real-time public reporting, registration, regulatory framework, regulatory requirements, reporting party, risk management, Scott O'Malia, SEC, Securities and Exchange Commission, Securities and Futures Commission, segregation, sell-side firms, shareholders, Singapore, substituted compliance, swap data recordkeeping, swap data reporting, swap data repository, swap dealer, swaps, swaps processing, third country, trade confirmations, transaction cost, transaction-level requirements, transparency, Trust, U.S. person, uncleared swaps, United Nations,

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,

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 […]

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