MFA Comment Letters

Topic: registered investment adviser

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 Comments in Response to SEC Proposed Amendments to Regulation D, Form D and Rule 15609.23.13


MFA submitted a letter to the Securities and Exchange Commission in response to proposed amendments to Regulation D, Form D […]

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Topics: accredited investor accredited investors, Advance Form D, adviser registration, anti-fraud rules, assets under management, AUM, Ban on General Solicitation and Advertising, beneficial owners, capital formation, capital markets, cease and desist, censure, CFTC, Colorado Bar Association, commodities, Commodity Futures Trading Commission, competition, compliance, compliance costs, cost-benefit analysis, deemed compliant, derivatives, disclosure requirements, Division of Investment Management, due diligence, efficiency, eligible purchasers, Elizabeth Murphy, equity, examination process, Federal Securities Laws, Form 13F, Form ADV, Form D, Form PF, Franklin Group of Funds, Fund Sponsors, general partner, General Solicitation, general solicitation materials, Global Investment Performance Standards, harmonization, hedge fund industry, hedge fund managers, hedge funds, high net worth requirements, institutional investor, interpretive guidance, investment company, Investor Protection, investor qualification standards, issuers, JOBS Act, John Thune, knowledgeable employees, legends, liquidity, market practices, marketing materials, mutual fund, natural persons, Norm Champ, OCIE, Office of Compliance Inspections and Examinations, Pacific Mutual Life Insurance Company, performance, pitch book, PLI Hedge Fund Management Conference, pool participants, private capital markets, private fund, private fund managers, private fund offerings, private placement memorandum, private placements, proprietary information, public markets, qualified clients, qualified purchasers, Ray Garrett, registered investment adviser, registered investment companies, Regulation D, retail investors, RICs, Rulemaking, Schedule 13D, SEC, Securities and Exchange Commission, sophisticated investors, state securities regulators, statement of policy, transparency, United States Congress, Variable Life, Verification Methods,

MFA Submits Letter and White Paper on Protection of Non-Public, Sensitive, and Proprietary Information by FSOC Members05.22.13


MFA submitted a cover letter and white paper to each member of the Financial Stability Oversight Council (FSOC) on the […]

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Topics: Adam Clark-Joseph adviser registration, Andrei Kirilenko, Board of Governors of the Federal Reserve System, broker-dealer, CFTC, CIGFO, clearinghouses, Commodity Futures Trading Commission, commodity pool operator, commodity trading advisor, confidentiality, Consumer Financial Protection Bureau, Council of Inspectors General on Financial Oversight, CPO, CTA, data collection, data repositories, DCO, Department of the Treasury, Designated Clearing Organizations, Dodd-Frank Act, FCM, FDIC, Federal Deposit Insurance Corporation, Federal Housing Finance Agency, Federal Insurance Office, financial stability, Financial Stability Oversight Council, Form CPO-PQR, Form CTA-PR, Form PF, front running, FSOC, futures commission merchants, harmonization, high frequency trading, information security program, inspector general reports, intermediary, investment advisers, Jaksa Cvitanic, legal entity identifiers, liquidation, Managed Funds Association, market participants, market structure, National Credit Union Administration, National Institute of Standards and Technology, NIST, Office of Financial Research, Office of the Comptroller of the Currency, President Obama, registered investment adviser, reporting, research, Reverse Engineered, Richard A. Shilts, Richard H. Baker, Rulemaking, SBSDR, SDR, SEC, SEC Office of Inspector General, Securities and Exchange Commission, Security-Based Swap Data Repositories, self-regulatory organization, SRO, substituted compliance, swap data repository, systemic risk, Trade Secrets, trade sectrets, Trading Activities, U.S. House of Representatives Committee on Financial Services, U.S. securities law,

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 […]

Letter to ERISA Advisory Council on Hedge Funds’ Benefit to Pensions and Beneficiaries11.01.11


MFA submitted a written statement to the ERISA Advisory Council in connection with an Advisory Council meeting on November 8 […]

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 SEC on Pay to Play Proposal10.06.09


MFA submitted a letter to the SEC today in response to its proposal to, among other things, restrict political contributions […]

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Topics: academic institutions affiliated broker-dealer, agency, American Bar Association, anti-competitive effects, assets, authority, backward-looking provisions, beneficial owners, Broker, broker-dealer, California Public Employees' Retirement System, CalPERS, CalSTRS, cash solicitation, charitable institution, chief compliance officer, chilling effect, code of ethics rule, Committee on Federal Regulation of the American Bar Association, compensation arrangements, compliance burden, compliance costs, compliance procedures, Connecticut, contractual rights and obligations, covered associates, covered investment pool, de minimi exception, Dealer, direct investment, direct investors, Disclosure, disproportionately severe punishment, due diligence, executive officer, family members of covered associates, fiduciary duty, Form ADV, Foundation, fund assets, fund of funds, general partner, government assets, government entities, government official, hedge fund managers, hedge funds, Illinois, inadvertent contribution, Inadvertent Violation, inauguration or transition committee, incentive fee structure, institutional investor, instrumentality of the State, interest, investment adviser, investment advisory services, investment management industry, investment management services, investment objectives, investment services, investment techniques, legal authorities, limited partnership, liquidity, local or state political party, look-back period, look-back provision, Los Angeles City Employees' Retirement System, Los Angeles County Employees' Retirement System, management fees, marketing activities, Massachusetts, MSRB, municipal securities, municipal securities business, municipal securities principals, municipal securities professional, municipal securities representative, Municipal Securities Rulemaking Board, municipal securities underwriters, municipal underwritings, New Mexico Educational Retirement Board, New Mexico Investment Council, New York, New York City Employees' Retirement System, New York State Common Retirement Fund, offshore managers, Oklahoma, operational challenges, pay to play practices, pay to play scandals, Pennsylvania Public School Employees' Retirement System, Pennsylvania State Employment Retirement System, pension, personal political activities, placement agent, plan, platform arrangement, political action committee, political contributions, pool of assets, pooled investment vehicle, portfolio manager, pre-approval policies, pre-approval procedures, principal business unit, private fund, program, public pension plans, publicly offered securities, redemption requests, redemption rights, registered investment adviser, registered investment companies, registration, regulations, Regulators, requests for proposals, returned contribution, risk management, sales principals, SEC, Securities and Exchange Commission, securities firms, soliciting, state and federal laws, state and local entities, Teacher Retirement System of Texas, third party placement agent, third party placement agents, third party solicitors, transparency, unregistered adviser, Wall St. Journal, Washington, written compliance policies and procedures,
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