MFA Comment Letters

Topic: PWG

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 Senate Republican Capital Markets Task Force Regarding United States Capital Markets Competitiveness in the Global Financial Services Marketplace02.29.08


MFA submits a comment letter to the Senate Republican Capital Markets Task Force in response to the Task Force’s request […]

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Topics: assets under management Blue Print for U.S. Financial Competitiveness, Canada, capital, capital efficiencies, capital formation, capital markets, Cendant, CFTC, chilling effect, commodity futures markets, Commodity Futures Trading Commission, Cross-Border, Department of the Treasury, duplicative regulation, Economic Club of New York, energy commodities, Enron Corporation, equity markets, EU, European Union, exchanges, Federal Energy Regulatory Commission, Federal Reserve Board, Federal Trade Commission, FERC, Financial Industry Regulatory Authority, financial regulatory system, Financial Services Forum, financial services industry, Financial Services Roundtable, FINRA, GAAP, General Advertising, General Solicitation, generally accepted accounting principles, global financial system, H-1B visa, harmonization, hedge funds, Henry Paulson, IFRS, International Financial Reporting Standards, investment advisers, Investor Protection, market crisis, market participants, mutual recognition, National Futures Association, natural gas futures market, NFA, no-action letters, non-U.S. investors, OCIE, Office of Compliance Inspections and Examinations, oil and gas partnerships, President's Working Group on Financial Markets, principles-based regulation, prudential regulators, public commodity pools, PWG, regulation, regulatory regime, retail investors, safe harbor, SEC, Secretary of the Treasury, Securities and Exchange Commission, Senate Republican Capital Markets Task Force, skilled non-U.S. professional workers, Strategy and Financial Innovation, student visa, tax, transparency, U.S. Capital Markets, U.S. immigration policies, United Kingdom, United States Congress, venture capital funds,

MFA Submits Letter to Department fo the Treasury Regarding Review by the Treasury Department of the Regulatory Structure Associated with Financial Institutions11.21.07


MFA submits letter to the U.S. Department of the Treasury in response to its request for recommendations on how to […]

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Topics: adequate disclosure Asian Countries, Australia, BaFin, bonds, business models, capital raising process, CFTC, collateral management stystems, collective investment vehicles, commercial, Commodity Futures Trading Commission, commodity pool operator, commodity pool operators, common stock, competitiveness concerns, compliance, conduct-of-business, conflicting regulatory edicts, Congress, costs, counterparites, cross-recognition efficiencies, crude oil, currency options template, customer protections, Department of the Treasury, derivatives, derivatives clearing organizations, Disclosure, duplicative systems, Europe, exchange, exchanges, fair prices, Federal Energy Regulatory Commission, federal government, FERC, Financial Industry Regulatory Authority, financial institutions, financial integrity systems, financial products, Financial Services Action Plan, Financial Services Roundtable, FINRA, flexibility, foreign markets, Fraud, fund of funds, funds, futures, futures brokerage commission payments, futures contracts, futures exchange, G-8 finance ministers and deputies, global alternative investment industry, gold, hedge fund investors, hedge funds, hedging, Henry Paulson, higher prices, intemediary brokerage firms, intermediaries, International Organization of Securities Commissions (IOSCO), international organizations, international portfolio valuation principles, international regulatory standards, Investor Protection, Japan's Financial Services Agency, liquid trading markets, local law enforcement, managed futures funds, margin area, margin levels, market and financial integrity, Market Particpants, market price transparency, marketplace, mutual, National Futures Association, natural gas, natural gas futures price manipulation, net capital, net long, Netherlands, NFA, optimal regulatory structure, options contracts, options trading, ownership interest, peer-to-peer guidance for hedge fund managers, Policy Makers, pool offerings, portfolio margining, Portfolios, President's Working Group on Financial Markets, principles-based approach, private pools of capital, private sector self-regulation, private transactions, prudential safety, public interest, public interest goals, public managed futures fund offerings, PWG, regions, regulation of intermediaries, regulatory framework, regulatory oversight, Regulatory Structure, retail customers, retail foreign exchange (FX), risk management, risk-based performance bond system, rules-based approach, safe harbor, SEC, securities, Securities and Exchange Commission, security futures, short, Sound Practices for Hedge Fund Managers, soundness regulation, state regulators, state securities regulators, statutory core principles, stock index, stock price, stock world, substantial inefficiency, tired system of regulation, trading business activties, trading platforms, transactions, twin peaks model, U.S. capital market competitiveness, underlying asset, uniform set of basic principles of regulation, United Kingdom's Financial Services Authority (FSA), United States, unwarranted costs, valuation, wheat, wholesale,

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 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 Comments to IOSCO on Consultation Report on Principles for the Valuation of Hedge Fund Portfolios06.21.07


MFA submits comment letter to IOSCO on its Consultation Report on Principles for the Valuation of Hedge Fund Portfolios.

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Topics: absolute return strategies advisory, advocate, anti-money laundering, business continuity, Business Continutiy and Disaster Recovery, CFTC, Checklist for Code of Ethics, Checklist for Compliance Manuals, Commodity Futures Trading Commision, conflicts of interest, Congress, consistency, data vendors, Department of the Treasury, derivative market practices, disaster recovery, Fair Value, Federal Reserve, financial instruments, financial statement close process, FSA, global alternative investment industry, global capital markets, global set of principles, governing body, government bodies, hedge fund management, hedge fund managers, hedge funds, independence, India, Instrument, internal trading controls, investment portfolio, Investment Portfolios, Investor Protection, investors, IOSCO, IOSCO Report, IOSCO's 2007 32nd Annual Conference, key market soundness, macro-level guidance, major dealers, Management and Internal Trading Controls, market prices, material obstacles, MFA's 2005 Sound Practices, mission-critical, Mumbai., NAV, net asset value, operational framework, organized exchanges, portfolio strategies, President's Working Group on Financial Markets, price validation, pricing poliies and sources, private sector, public, PWG, Regulatory Controls, Responsibilites to Investors, risk management, risk monitoring, SEC, Securities and Exchange Committee, Securities Exchange Board of India, state agencies, third parties, Third Party Service Providers, Transactional Practices, transparency, U.S. regulatory Filings, United Kingdom's Financial Services Authority, United States, valuation, valuation of investments, Valuation Policies and Procedures,

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 Comment Letter to FSA Regarding Discussion Paper “Hedge funds: A discussion of risk and regulatory engagement”10.28.05


MFA Comment Letter to UK’s FSA re: Discussion Paper on Hedge Funds

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Topics: absolute return Absolute Return Magazine, absolute return strategies, AIMA, alternative investment industry, Alternative Investment Management Association, assets under management, AUM, bank, Ben Bernanke, Board of Governors of the Federal Reserve System, Canada, Cash Flow, cash management, CFTC, collateral, Commodity Futures Trading Commission, compliance burden, counterparties, counterparty risk management policy, credit derivatives, credit risk, dealers, Delaware, Department of the Treasury, derivatives, derivatives markets, derivatives transactions, disclosures, drawdown, due diligence, Fair Value, financial instrument, Financial Services Authority, Fraud, FSA, FTSE-250, fund of funds, GAAP, generally accepted accounting principles, global financial marketplace, Greenwich Roundtable, Guide to Sound Practices for European Hedge Fund Managers, hard-to-value, hedge fund administrator, hedge fund adviser, hedge fund industry, hedge fund managers, hedge funds, high net worth requirements, illiquidity, implications of the growth of hedge funds, industry-led initiatives, institutional investors, internal controls, internal trading controls, International Organization of Securities Commissions, International Swaps and Dealers Association, investment bank, investors, IOSCO, ISDA, leverage, liquidity, liquidity risk, London, Long Term Capital Management, managed futures funds, market participants, market risk, MFA's 2005 Sound Practices, MFA's Sound Practices for Hedge Fund Managers, NAV, net asset value, net worth, New York, novation protocol, novations, Office of Risk Assessment, offshore, operational risk, Policy Makers, pooled investment vehicle, Portfolio Diversification, portfolio manager, President's Working Group on Financial Markets, price discovery, private equity, private funds, PWG, real estate funds, Redemption, regulatory arbitrage, regulatory framework, regulatory oversight, retail funds, risk, risk management, risk position, Robert Jaeger, Roel Campos, S&P 500, SEC, Securities and Exchange Commission, segregation, self-regulatory organization, short selling, side pockets, single-manager hedge funds, soft commission, sophisticated investors, Sound Practices, SRO, stress testing, trade associations, Transactional Practices, United Kingdom, United States, valuation, venture capital,
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