MFA Comment Letters

Topic: redemption policy

Comment Letter to ESMA on its Draft Technical Advice to the European Commission for Implementing AIFMD09.13.11


MFA submitted comments to ESMA on its consultation on possible implementing measures of the Alternative Investment Fund Managers Directive (AIFMD). […]

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Topics: Advanced Method Advisers Act, AIF, AIFMD, Article 3(2), Article 61, Article 9(3), AUM, AUM Calculations, bespoke system, Box 1, Box 106, Box 13, Box 19, Box 2, Box 29, Box 78, Box 79, Box 81, Box 86, Box 88, Box 89, Box 93, Box 95, Box 99, CDS, CESR Guidelines, collateral, collateral directive, Commitment Method, Committee on European Securities Regulators, confidentiality, consultation paper, counterparties, counterparty exposures, credit default swap, depositaries, depositary, diligence requirement, Dodd-Frank, due diligence, ECB, EU investors, EU Passport, European Central Bank, European Commission, exposure, Financial Services Authority, foreign exchange hedging position, Form PF, FSA, G-20, gates, generally accepted accounting principles (GAAP), Gross Method, interest rate hedging position, international coordination, Investment Advisers Act of 1940, Level 2, Level 2 inputs, Level 3 inputs, leverage, liability regime, liability standards, liquidity risk, mark-to-market, market risk, marketing, MiFID, NAV, net asset value, omnibus accounts, operational risk, OTC transaction, passport regime, portfolio management, portfolio risk, prime brokers, private funds, professional indemnity insurance requirements, professional investors, proprietary information, re-hypothecation provisions, redemption policy, registration, remuneration, reporting period, repurchase agreement, retail investors, risk limits, risk management, safe-keeping function, SEC, securities lending agreement, segregation, semi-annual reporting, side pockets, sub-custodian, sub-investment managers, systemic risk, the directive, third party managers, transparency, U.S. Securities and Exchange Commission, UCITS Directive, underwriters, unobservable, valuation agents, Value at Risk, VaR,

Comment Letter to Responding to ESMA’s Call for Evidence Regarding Level 2 Implementation of the Alternative Investment Fund Managers Directive01.14.11


On January 14, MFA submitted comments to the European Securities and Markets Authority (ESMA) in response to a call for […]

MFA Comments to IRS on Application of FBAR to Private Investment Funds and Related Issues10.05.09


MFA submitted a letter to the IRS in response to IRS Notice 2009-62, which requests comments and recommendations concerning the […]

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Topics: bank account banks, broker-dealer, chief financial officer, commingled fund, Corporation, covered foreign financial account, Deferred Fees, Department of the Treasury, domestic corporation, domestic estate or trust, domestic partnership, domestic taxpayers, Douglas H. Shulman, effectively connected income, FBAR, filing obligation, financial accounts, Financial Crimes Enforcement Network, financial institutions, financial interest, FinCEN, FIRPTA, foreign corporations, foreign financial account, foreign financial agencies, foreign prime brokerage, Form 1065, Form 5471, Form 8621, Form 8865, Form 926, hedge fund management companies, hedge fund manager, hedge funds, Internal Revenue Code, Internal Revenue Service, investment fund management company, Investment Fund Managers, investment officer, investors, IRS, James H. Freis, liquidity, Lock-up, master fund, Michael Mundaca, money laundering, mutual funds, Neal S. Wolin, New York State Bar Association, non-public companies, non-U.S. hedge fund, non-U.S. hedge funds, non-U.S. investors, non-U.S. private equity fund, officer, open-ended mutual funds, Other Account Authority, other authority, partner, partnership, Passive Foreign Investment Companies, persons in and doing business in the United States, PFIC shareholder filing requirements, PFICs, portfolio manager, primary owner, private equity funds, private investment funds, private sector, publicly-held companies, redemption policy, redemption terms, Reports of Foreign Bank and Financial Accounts, safe harbor, securities account, shareholders, signatory authority, Tax Section of the New York State Bar Association, third party transfers, U.S. tax return, U.S.-based manager, U.S.-based managers, United States Person, Workbook on the Report of Foreign Bank and Financial Accounts,
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