MFA Comment Letters

Topic: Rulemaking

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 Comment Letter to CFTC on Proposed Dodd-Frank Implementation Rules for Mandatory Swap Clearing, Trade Execution, and Margin Rules11.04.11


The OTC derivatives reforms (Title VII) resulting from the Dodd-Frank Act will cause sweeping transformation of the OTC derivatives markets […]

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Topics: active fund bilateral execution, broad-based index credit default swaps, buy-side market participants, buy-side participants, Category 1 Entities, Category 2 Entities, Category 3 Entities, Category 4 Entities, CCP, central clearing, central counterparties, CFTC, class of swaps, clearing, clearing mandate, collateral, Commodity Futures Trading Commission, commodity swaps, compliance date, compliance schedules, cost-benefit analysis, counterparties, DCMs, derivatives clearing organization, Designated Contracts Markets, Dodd-Frank Act, electronic platform, end-user exemptions, exchanges, execution, execution venue, FCM, federal register, full-scale clearing, futures commission merchants, G20, Gary Gensler, interest rate swaps, liquidity, listing, made available for trading, Major Security-Based Swap Participant, Major Swap Participant, mandatory clearing, margining, margining requirements, market participants, netting, non-dealer market participants, non-MSP counterparties, novations, OTC derivatives, over-the-counter derivatives, partial tear-ups, phased implementation, price distortion, private funds, product definition rules, prudential regulators, real-time clearing, real-time reporting, Regulators, Rulemaking, Scott O'Malia, SEC, Securities and Exchange Commission, Security-Based Swap Dealer, security-based swap SEF, security-based swaps, SEF, swap data, swap dealer, swap execution facilities, swap transaction, swap transaction compliance, swaps, systemic risk, third-party subaccount, trade execution, trading documentation, transparency, uncleared swaps, variation margin, voluntary clearing,

Comment Letter on CFTCs Proposed Rule Related to Requirements for Derivatives Clearing Organizations, Designated Contract Markets, and Swap Execution Facilities Regarding the Mitigation of Conflicts of Interest11.17.10


On November 17, MFA submitted a comment letter on the CFTCs proposed rule related to Requirements for Derivatives Clearing Organizations, […]

MFA Comments in Response to the IOSCO Consultation Report on Hedge Funds Oversight04.30.09


MFA submitted a written response to the IOSCO Consultation Report on Hedge Funds Oversight. MFA’s comments focused on four key […]

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Topics: absolute return advisory relationships, alternative investment fund managers, Alternative Investment Management Association, Anti-Fraud Provisions, banking, best practices, bilateral solutions, business-process objectives, buyers, capital, capital markets, CDS, centralized clearing, clearinghouse platforms, Commission Bancaire of France, counter-cyclical force, credit default swaps, customer collateral, diligence process, distressed assets, EC, endowments, equities, equity derivative confirmations, European Commission, Fannie Mae, Federal Reserve Bank of New York, Financial Research Corp. counterparties, Financial Stability Forum, Freddie Mac, FSA, G-20, global crisis, global integration, Hedge Fund Standards Board, hedge funds, Hedge Funds Oversight: Consulation Report, high-water mark, insider trading, investor confidence, Investor Protection, IOSCO, Lehman Brothers, liquidity, Long Term Capital Management, Lord Adair Turner, management fee, Market Confidence, market integrity, MFA's Sound Practices for Hedge Fund Managers, minimum capital requirements, moral hazards, mutual fund, OMG, Operations Management Group, orderly dissolution, OTC derivatives, over-the-counter derivatives, pension plans, performance compensation, President's Working Group's Asset Managers' Committee, price efficiency, prime brokers, private pools, proprietary information, public disclosure, regulation, residential mortgage lending, Rulemaking, securities laws, sellers, selling short, stability, standardized disclosures, systemic risk, Task Force on Unregulated Financial Entities, Technical Committee of the Internationl Organization of Securities Comissions, transparency, U.K. Financial Services Authority,

MFA Letter to SEC Chairman Cox Regarding Hedge Fund Transparency and Other Issues04.24.08


MFA President and CEO, Richard H. Baker, met with SEC Chairman Christopher Cox this morning and discussed the topics addressed […]

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Topics: accredited investors accredited natural person, advertising materials, alternative investment industry, annual cap, Australia, Ban on General Solicitation and Advertising, best practices, broker-dealer, brokers, Canada, capital markets, CFTC, chief compliance officer, Christopher Cox, Clover Capital no-action letter, Commodity Futures Trading Commission, Cross-Border Investments, Direct Participation Programs, Division of Investment Management, DPP, EU, European Union, Federal Securities Laws, Financial Industry Regulatory Authority, financial services industry, FINRA, futures, futures market, General Advertising, General Solicitation, global capital markets, hedge fund investors, hedge fund managers, hedge fund offerings, hedge funds, Implications of the Growth of Hedge Funds Staff Report to the United States Securities and Exchange Commission, inflation, investors, large accredited investor, lifetime cap, managed futures, market participants, Memorandum of Understanding, mutual recognition, Nancy Morris, National Futures Association, NFA, no-action letters, NYRO OCIE, offering proceeds, Policy Makers, pooled investment vehicle, private offerings, Protecting Investors: A Half Century of Investment Company Regulation, public commodity pool offerings, public commodity pools, public offering disclosure requirements, qualified purchasers, Regulation D, Regulators, regulatory barriers, Rulemaking, safe harbor, SEC, securities, Securities and Exchange Commission, sophisticated investors, Sound Practices for Hedge Fund Managers, staff guidance, systemic risk, trade associations, trail commissions, transaction costs, transparency, United States Congress,

MFA Comments to U.S. Federal Banking Agencies on Capital Treatment of Equity Investments in Hedge Funds by Banks in Proposed Regulations Implementing Basel II International Capital Accords06.21.07


MFA submits comment letter to the U.S federal banking agencies on the capital treatment of equity investments in hedge funds […]

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