MFA Comment Letters

Topic: regulations

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,

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 SEC on August 2007 New York Regional Office Examination Request Letter12.20.07


MFA submits comments to the SEC on the August 2007 New York Regional Office Examination Request Letter.

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Topics: adviser advisers, and VI(B)(1), arrangements, attorney-client privilege, August 2007 New York Regional Office Examination Request Letter, bankruptcy workout, broker-dealer, candidates, CCO Seminars or Roundtables, CCOutreach National Seminar, chief compliance officer seminars and roundtables, Chief Compliance Officers, Code of Ethics, compliance, complianceAlert, conflicts of interest, consistency, corporate insiders, data mining, Director of SEC's Office of Compliance and Inspections and Examinations, examination process, Federal Securities Laws, focus group, Form ADV Part II, hedge fund advisers, I(G), II(A)(2), II(A)(3), II(H)(1), III(M)(1), III(M)(3), III(N)(1), III(N)(2), IIIJ(1), Investor Protection, IX(F)(2)m X(I)(2), legal risk, Lori A. Richards, medium, Microsoft Excel spreadsheets, National society of compliance Professionals National Membership Meeting, New York Regional Office, Ninth Annual IA Compliance Best Pracitces SUmmit 2007, Office of Compliance Inspections and Examinations (OCIE), operations, periodic examinations, Pilot program, portfolio allocation, potential transactions, pre-examination letters operational resources, public, public company affiliation, public pension funds, registered investment advisers, registrants, regulations, relative, reqests II(D)(1), Request II(A)(1), Request II(B)(3), Request II(D)(3)(e), Request II(G)(1), Request II(J)(1), Request IV(A)(1)m block trades, Request V(A)(4), request V(G)(1), risk-based approach, risks, sales coverage, SEC, Securities and Exchange Commission, shareholder communications, standardized presentations, surveillance, technology, V(E)(2), V(E)(3), VIII(G), written complaint,
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