MFA Comment Letters

Topic: private funds

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 Letter in Response to SEC Investor Advisory Committee Recommendations on Implementation of the JOBS Act03.22.13


MFA submitted a comment letter to the Securities and Exchange Commission (SEC) in response to its proposed implementation of Section […]

MFA Submits Letter to IRS on Proposed Rules on Dividend Equivalent Payments04.06.12


MFA submitted a comment letter to the Internal Revenue Service on the IRS proposed rules under Section 871(m) of the […]

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Topics: 30 day liquidity 90-Day Rule, abusive practices, ADTV, anti-abuse rule, average daily trading volume, Bloomberg, broad-based indices, cascading witholding taxes, common stock, compliance restrictions, contractual representations, credit, crossing, crossing transactions, customized index, delta, delta one instrument, delta-one, delta-one instruments, Department of the Treasury, derivatives, derivatives transactions, direct or indirect "cross", dividend equivalent, dividend equivalent payments, dividend payment, dividend swaps, equity linked derivatives markets, equity-linked swaps, extraordinary dividend, FATCA, full notional amount, future dividend flow, futures, gross witholding, hedge, high-frequency trading, illiquid securities, in connection with standard, in the market, individual trade determinations, Internal Revenue Service, internal tax review system, International Swaps and Dealers Association, investment algorithms, investment fund, IRS, ISDA, leverage, long equity swap, long-party, market forces, market participants, market sector, multi-strategy fund, non-delta one instrument, non-U.S. persons, OCC, offsetting position, options, Options Clearing Corporation, options contracts, options market, ordinary divident, OTC option, out-of-the-money, outstanding positions, overwitholding, preferred stock, private funds, proprietary index, public float, public float test, real-time identification of offsetting positions, recognized independent index publisher, retested, short-party, short-term trades, single strategy fund, SNPC, special dividend, special dividends, specified notional principal contracts, strike price, swaps, synthetic exposure, tax avoidance, trading strategies, underlying security, undue market disruption, witholding agent,

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

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,
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