MFA Comment Letters

Topic: private equity

MFA Submits White Paper to European Commission on Shadow Banking06.01.12


On June 1, MFA submitted a white paper on hedge funds and shadow banking in response to the European Commission’s […]

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Topics: "too big to fail ABCP conduits, absolute risk, AIFMD, Alternative Investment Fund Managers Directive, asset classes, asset-backed commercial paper conduits, asset-backed securities, assets under management, AUM, Background Note, Background Note "Shadow Banking: Scoping the Issues", bank-like activities, bank-like regulation, bankruptcy, banks, Board of Governors of the Federal Reserve System, broker-dealer, Brookings Institution, Bureau of Economic Analysis, central clearing, CFTC, chief compliance officer, collateral, Columbia University, commodity futures contracts, Commodity Futures Trading Commission, commodity pool, commodity trading advisor, convertible arbitrage, corporate bonds, corporate fixed income instrument, counter-cyclical, counterparties, credit arbitrage strategies, credit cards, credit hedge funds, credit intermediation, creditor, CTA, demand deposit accounts, Department of the Treasury, deposit-like characteristics, derivative transactions, derivatives, derivatives market, direct lending, direct loan market, discount windows, distressed restructuring strategies, Dodd-Frank Act, Dodd-Frank Wall Street Reform and Consumer Protection Act, Doug Elliott, EMIR, equity investors, EU, EU Member State, European Commission, European Market Infrastructure Regulation, European Union, financial industries, financial institutions, financial market, Financial Services Authority, Financial Stability Board, Financial Stability Oversight Council, fixed income - asset backed, fixed income - convertible arbitrage, fixed income - corporate, fixed income instruments, Form ADV, Form PF, FSA, FSB, FSOC, fundamental credit analysis, G20, gates, government bonds, government insurance, Green Paper "Shadow Banking", hedge fund counterparties, hedge fund industry, hedge fund managers, Hedge Fund Research, hidden leverage, House Financial Services Subcommittee on Financial Institutions and Consumer Credit, ICI, initial margin, insider trading, instant liquidity funds, institutional investment manager, investment advisers, Investment Company Institute, investment strategies, investor, leverage, leverage ratio, leveraged loan markets, liquidity, liquidity protections, liquidity transformation, loans, lock-up periods, Long Term Capital Management, Lord Adair Turner, major swap participants, margin, market based regulations, Markets in Financial Instruments Directive, Master Limited Partnership, maturity tra, maturity transformation, MiFID, money market funds, mutual funds, mutual funds management, non-bank financial insitutions, nonbank credit intermediation, Office of Financial Research, OFR, originator, OTC derivatives, over-the-counter derivatives, PIPE, pricing discrepancy, private equity, private investment in public equity, private issue/Regulation D strategies, property-casualty insurance, prudential regulation, public company equity securities, quantitative strategies, RAUM, real estate, receivables, redemption terms, Regulation D, regulatory arbitrage, regulatory assets under management, regulatory framework, relative value, relative value - multi-strategies, risk analysis, risk management, SEC, secured borrowings, secured financing, Securities and Exchange Commission, segregation, shadow banking, shadow banking system, side pockets, SIFI, SIV, small and medium-sized enterprises, SME, sophisticated investors, state securities regulators, structured investment vehicles, swap dealers, swaps, systemic risk, systemically important financial institution, tangible financial commitments, taxpayer, the Fed, total return swaps, transparency, U.S. Securities Laws, uncollateralized loans, United Kingdom, variation margin, venture capital funds, Volcker Rule,

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

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Topics: absolute return strategies aggregate borrowings, aggregate gross asset value, alternative methodology, asset-backed securities, assets under management, audited financial statements, balance sheet value, beneficial owners, bespoke contracts, Bloomberg, borrowing arrangements, CCPs, CDS, CDX, central clearing counterparties, CFTC, clause (iii), collateral, collateral practices, commodity pool operators, commodity trading advisors, confidentiality of information, confidentiality protections, corporate bonds, Council and Office of Financial Research, counterparty exposures, CR01, creditor, currency rates, CUSIP number, DCMs, de minimis, debt securities, default rates, delta adjusted, direct clearing members, direct investments, distressed debt, Dodd-Frank Act, duration, DV01, equity derivatives, equity exposure, equity prices, FCMs, Federal Reserve System, Financial Accounting Standards Board, Financial Stability Oversight Council, five-year option, fixed advisory fees, foreign currency contracts, foreign exchange derivatives, Form 10-K, Form 10-Q, Form 13F, Form ADV, Form CPO, Form CTA-PR, Form PF, Form PF question 36, form PF questions 28 and 35, Form PQR, FSA, funds of funds, futures commission merchants, futures contracts, GAAP, generally accepted accounting principles, global regulators, GMV, gross asset value, hedge fund assets under management, hedge fund defaults, illiquid assets, inadvertent disclosure, inception class, individual certification, interconnectedness, interest rates, interpretive guidance, Investment Adviser Registration Depository, investment advisers, investment expenses, large private fund manager, lending institutions, Level 2 inputs, Level 3 inputs, leverage, liquidity management, liquidity risk, LMV, loan commitments, long positions, managed futures, margin requirements, market noise, market participants, market value, master agreement, master-feeder, maturity brackets, maturity mismatch, NAV, net asset value, net assets under management, net borrowings, non-bank financial companies, non-rated issues, notional amount, notional value of derivatives, offsetting exposure, OFR, operational capabilities, operational efficiency, other quantitative strategies, overcounting, parallel funds, parallel managed accounts, performance fees, portfolio management, prime brokers, private equity, private fund managers, private funds, privately issued convertible bonds, proposed reporting thresholds, proprietary information, proprietary methodology, public companies, qualifying fund, record owners, recordkeeping requirements, regulatory assets under management, regulatory scrutiny, rehypothecated initial margin, reporting period, repos, risk capital allocation, risk methodology, Schedule 13G, SEC, section 404, semi-annual reporting, sensitivity analyses, short borrowing, short positions, short term high quality corporate debt, short-term interest rate, short-term market fluctuations, side pocket arrangement, SMV, statistical arbitrage-equity, strategy exposure, swap contracts, synthetic borrowing, systemic risk, systemically significant, targeted requests, ten-year option, the Fed, threshold, threshold for enhanced performance, tiered reporting system, trading and investment strategies, tri-party collateral accounts, turnover rate, UK Financial Services Authority, unaffiliated third party sources, uncommitted lines of credit, undercounting, valuation methodology, Value at Risk, VaR, variation margin,

MFA Letter to IRS Regarding Compliance Issues for Private Investment Funds Filing a Foreign Bank and Financial Accounts Report05.13.09


MFA submitted a letter as a follow up to its meeting on April 7 with officials from the IRS to […]

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Topics: adverse guidance AML program rule, banks, Betty Santangelo, board directors, bonds, brokerate accounts, Carl E. Kennedy, checking, commodity pool operators, commodity trading advisors, compliance, control the disposition, cost-efficient, covered financial accounts, demand, deposit, derivatives, Detroit Computing Center of the Internal Revenue Service, domestic feeder fund, domestic limited liability companies, domestic limited partnerships, Don Carbaugh, Don Moorehead, equity interest, FBAR, FBAR Requirements, federal register, federal tax return, filing exception, Financial Crimes Enforcement Network, FinCEN, flow through, Foreign Bank and Financial Accounts Reports, foreign currencies, foreign securities, Form 1040, Form 1065, Form 1120, Form 5500, Form 990, Form 990-PF, Form TD 90-22.1, Form TD F 90-22, Form TDF 90-22.1, Fund Managers, general definitions, Glen Kirkland, group filings, hedge funds, illiquid, Internal Revenue Service, interpretive guidance, IRS, IRS Reports Clearance Officer, John G. Gaine, legislators, limited liability companies, lock-up periods, master-feeder structures, mutual fund, Nancy Rose, notes, Office of Chief Counsel, OMB No. 1545-2038, Partnerships, Patton Boggs LLP, pooled interest, President's Working Group on Financial Markets, prior submissions, private equity, private investment funds, publicly-traded corporations, PWG, Question 7a, Question 9, Questioon 6a, regulations, savings, schedule B, Schedule N, Schulte Roth & Zabel LLP, Side-by-Side Structure, signature authority, SRZ, stock certificates, tax forms, tax-exempt organization, taxpayer identification number, U.S. tax-exempt investors, United States Department of the Treasury, William Langford,

MFA Letter to GAO Following Telephone Interview on January 15, 200902.06.09


MFA submitted a letter to the Government Accountability Office (GAO) following its telephone interview on January 15, which was held […]

MFA Comment Letter to Canadian Securities Administrators on Registration Reform06.29.07


MFA submits comments and attachment to the Canadian Securities Administrators on Canadian registration reform.

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Topics: (NI31-103) absolute return strategies, accredited investors, accredited natural person, Administrative Costs, adviser registration, advisers, Alberta Securities Commission, alternative investment history, alternative investment opportunities, alternative investment vehicles, annual income threshold, assets under management, AUM, Autorite des Marches Financiers, British Columbia Securities Commission, broker-dealer, Canada, Canadian Securities Administrators', capital, capital markets, capital raising, CFTC, commodity futures, Commodity futures act, Commodity Futures Trading Commission, CSA, dealer registration exemption, dealer registration requirements, dealer registrayion exemption, defined term, Department of the Treasury, disclosure obligations, distressed, educational outreach, EU, European Union, exempt market trades, exposure, Federal Reserve Board, financial eligibility, financial institutions, financial markets, financing, flow-through analysis, Fraud, fund of funds, fund units, fund-of-funds, funds, global alternative investment industry, global financial marketplace, grandfather provision, hedge fund consultant, hedge fund industry, hedge funds, hedging, income tests for inflation, international capital markets, international investment fund manager, international portfolio manager, investment company, investment sophistication, Labrador, large activist posistions, leveraged buyout, limited market dealers, liquidity, managed futures funds, Manitoba Securities Commission, market intermediaries, National instrument 45-106, natural persons, net worth threshold, New Brunswick Securities Commission, Non-Canadian Hedge Fund Securities, Non-Ontario Regime, non-resident dealers, non-resident exemptions, Nova Scotia Securities Commission, offering document, offering memorandum, offshore investment vehicles, oil and gas, Ontario Regime, Ontario registered dealer, Ontario Securities Commission, pension plans, policymakers, pooled investment products, President's Working Group on Financial Markets, price efficiency, private equity, private equity funds, private investment vehicles, private placement, private pools of capital, privately offered fund, professional investment management for hedge fund managers, Proposed National Instrument 31-103, Prospects and Registration Exemptions, prospectus exemption, PWG, real estate funds, Register of Securities Northwest Territories, Register of Securities Nunavut, Register of Securities Prince Edward Island, Register of Securities Yukon Territory, registered broker-dealer, registration requirements, regulation, regulatory authorities, Regulatory Authority, regulatory regimes, retirement plans, risk distribution, risk-adjusted performance, Saskatchewan Financial Services Commission, securities, sophisticated investors, standards, Superintendent of Securities Newfoundland and Labrador, U.S. federal securities laws, United Kingdom, venture capital, well-developed capital markets, White Paper,

MFA Submits Comments to SEC on Proposals for Accredited Natural Person and Antifraud Rules03.09.07


MFA submits comment letter and attachment to the SEC on Proposals for Accredited Natural Person and Antifraud Rules.

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Topics: 100 beneficial owners 3(c)(1) funds, 3(c)(7) funds, accounting officers, accredited investor, accredited investor standard, Accredited Natural Person Proposal, alternative investment industry, American Bar Association, antifraud proposal, attorneys, beneficial owners, broker dealers, brokers, capital markets, cash room, Christopher Cox, competition, compliance, conflicts of interest, deferred compensation, Department of the Treasury, dialogue, direct investment, due diligence, eligible contract participant, ERISA Issues, financial eligibility standard, financial eligibility standards, fund employees, Goldstein decision, grandfathering provision, hedge funds, illiquid investments, incentive compensation, industry innovation, Investor Protection, joint property, Jonathan Shieber, legal counsel, Limited Partnership Agreement, liquidity, Lock-up, managed futures funds, management, net worth, net worth threshold, Office of Economic Analysis, operational, pooled investment vehicles, President's Working Group on Financial Markets, price efficiency, private equity, private investment vehicles, private placement memorandum, private pools, Prohibition of Fraud by Advisers to Certain Pooled Investment Vehicles, Pui-Wing Tam, PWG, qualified client, qualified eligible person, qualified institutional buyer, qualified purchaser, Randal Quarles, real estate, Regulatory Structure, Request for Proposal, research analysts, risk distribution, risk-adjusted performance, Robert Steel, scienter, SEC, Securities and Exchange Commission, Senate Committee on Banking Housing and Urban Affairs, side letters, start-up funds, Stephen Heuser, Stuatory Authority, Subscription Agreement, tax issues, Thomas Lemke, traders, transfer procedures, transparency, U.S. economy, venture capital, withdrawal,

MFA Submits Comments to IOSCO on Consultation Report on Hedge Funds Offered to Retail Investors05.31.06


MFA Submits Comments to IOSCO’s “Regulatory Environment for Hedge Funds” survey

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Topics: absolute return strategies accredited investors, alternative investment industry, assets under management, AUM, CFTC, client, Code of Ethics, Commodity Futures Trading Commission, commodity pool operator, commodity trading advisor, conflict of interest, Consultation Report on Hedge Funds Offered to Retail Investors, CPO, credit derivatives, CTA, dealers, Department of the Treasury, derivatives, due diligence, Fair Value, Federal Reserve System, Federal Securities Laws, fraudulent behavior, FTSE-250, fund of funds, futures, futures exchange, hard-to-v, hedge fund industry, hedge fund managers, hedge funds, illiquid investments, implications of the growth of hedge funds, institutional investors, International Organization of Securities Commissions, investment advisers, investment company, investor, IOSCO, IOSCO Technical Committe Standing Committee on Investment Management, Look Through, managed futures funds, MFA's 2005 Sound Practices, MFA's Sound Practices for Hedge Fund Managers, National Futures Association, NAV, net asset value, NFA, options contracts, pooled investment vehicle, pricing, private equity, private fund, real estate funds, registered investment companies, registered public offerings, regulation, Regulation D, reporting requirements, RICs, S&P 500, SC5 2003 Report, SEC, Securities and Exchange Commission, Senate Banking Subcommittee on Securities, side pocket, single-manager hedge funds, sophisticated investors, The Regulatory Environment for Hedge Funds, United States Congress, valuation, venture capital,
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