MFA Comment Letters

Topic: pooled investment vehicles

Comment Letter to the SEC on Establishment of a Registration Regime for Municipal Advisors as Required by the Dodd-Frank Act.02.22.11


MFA submitted a comment letter to the SEC in response to its proposal to establish a registration regime for municipal […]

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Topics: ABN AMRO Bank N.V. affiliate letters, ancillary services, bank deposits, CFTC regulation, commodity for future delivery, commodity trading advisors, common control, CTAs, dually-registered investment advisers, duplicative registration, exempt reporting advisers, foreign private advisers, Form ADV, Form MA, guaranteed investment contracts, investment advisers, investment advisory services, investment strategies, Kleinwort Benson Investment Management Limited, mid-sized adviser, multi-jurisdictional advisory firms, municipal advisor, municipal advisors, municipal advisory activities, municipal derivatives, municipal escrow investments, municipal financial products, municipal securities, Murray Johnstone Holdings Limited, no-action letters, option, participating affiliate agreements, pay to play rule, pooled investment vehicle, pooled investment vehicles, pools of assets, primary investors, private adviser exemption, private fund advisors, private fund managers, registered advisor, registered broker-dealer, registered CTAs, registered investment advisers, regular oversight, regulated persons, Royal Bank of Canada, SEC, SEC No-Action Letter, SEC oversight, SEC regulation, SEC resources, SEC-registered entities, Securities and Exchange Commission, securities futures product, Security-Based Swap, self-regulatory entity, solicitation, state entity, state securities commission, state-registered investment advisors, third-party solicitor, transition period for registration, Uniao de Banco de Brasileiros, venture capital funds,

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 to the Canadian Securities Administrators, Responding to Proposed Amendments to National Instrument 31-103, Registration of non-Canadian Investment Fund Managers01.13.11


On January 13, MFA filed a comment letter with the Canadian Securities Administrators in response to the CSAs proposed amendments […]

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,

MFA Comments to SEC Regarding Proposals to Revise Limited Offering Exemptions in Regulation D10.19.07


MFA submits a comment letter to the SEC regarding their proposals to revise the limited offering exemptions in Regulation D.

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Topics: 20% beneficial owner Accerdited Investor, accounting officers, accredited investor, accredited natural person, affiliated issuer, attorneys, bad actor disqualification provisions, beneficiaries, blue sky filing, brokers, capital, capital formation, cease and desist, committed capital, compliance, deferred compensation, director, Disqualification Provisions, Division of Enforcement, dollar-amount thresholds, dollar-amount threshols, due diligence, economic efficiency, equity owners, executive officer, federal regulations, financial eligibility standard, financial sophistication standards, flexibility, Form D, Fraud, fund principals, Future Inflation Adjustment, General Advertising, general partner, General Solicitation, global alternative investment industry, grandfather provision, Grandfathered, hedge funds, higher dollar-amount thresholds, implications of the growth of hedge funds, inflation, inflation adjustments, Interation Safe Harbor, investments tests, investor, Investor Protection, Investor relations professionals, Issuer, issuers, joint income thresholds, Joint Investments, knowledgeable employees, limited announcement, Limited Coffering Exemptions, managed futures funds, managing member, Manner of Offering, marital assets, natural persons, net worth, offering, Offerings, offers, Office of Economic Analysis, operational, policymaker, pooled investment fund, pooled investment funds, pooled investment vehicles, predecessor, primary beneficiary, private placement, private placement offerings, Private Pooled Investment Vehicle Release, privated pools of captial, promoter, Public Offerings, qualification, qualified client, Qualified Client Definition, qualified purchaser, Qualified Purchaser Definition, qualifies purchasers, recdivism, research analysts, retention tool, risk, risk/return, sale limitations, SEC, securities, Securities and Exchange Commission, senior financial, Sophisticated Investor Standards, sophisticated investors, sotck, start up company, subscription agent, Subscription Agreement, threshold, traders, traders of a fund affiliate, transaction costs, transactions, transparency, Trust Grantors, Trustees, U.S. Congress, United States,
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