MFA Comment Letters

Topic: Security-Based Swap

Comment Letter to SEC and CFTC Regarding Definition of ‘Eligible Contract Participant’01.10.12


MFA and SIFMA submitted a letter and attachment to the CFTC and the SEC on their proposed definition of “eligible […]

Comment Letter to SEC and CFTC on Proposed Rules Defining ‘Swap,’ ‘Security-Based Swap,’ and ‘Security-Based Swap Agreement,’ and Guidance on Mixed Swaps and Security-Based Swap Agreement Recordkeeping07.22.11


MFA submitted comments to the SEC and CFTC in response to their request for comments on their proposal on the […]

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Topics: 1993 energy exemption alternative delivery procedures, alternative transfer structure, antifraud liabilities, assignment and assumption agreements, bankruptcy estate, beneficial ownership interest, book-out contracts, business conduct requirements, capital, central clearing, CFTC, commodities, Commodity Futures Trading Commission, current debtor-creditor relationship, deferred shipment, delivery, direct or indirect ownership, eligible contract participants, energy commodities, exchange trading, Federal Securities Laws, forward contract exclusion, further definitions of swap, grantor, institutional investors, lender of record, liquidity, LMA, loan agreement, loan arrangers, loan market association, loan markets, loan participants, loan participations, loan payments, Loan Syndications and Trading Association, loan total return swaps, loan transfer mechanism, LSTA, margin, market participants, material non-public information, mixed swaps, netting, non-U.S. counterparties, nonfinancial commodity, oil, OTC derivatives, participant, participation agreements, physical commodity, physically settled, primary loan markets, private market, recordkeeping, reference loan, reporting, SEC, secondary loan markets, Securities and Exchange Commission, security, Security-Based Swap, security-based swap agreement, security-based swap agreement recordkeeping, syndicated loan market, synthetic exposure, systemic risk, total return payer, total return receiver, true participants, true participation, true sale, U.S. domiciled counterparties,

Comment Letter to the SEC on Establishment of a Registration Regime for Municipal Advisors as Required by the Dodd-Frank Act.02.22.11


MFA submitted a comment letter to the SEC in response to its proposal to establish a registration regime for municipal […]

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Topics: ABN AMRO Bank N.V. affiliate letters, ancillary services, bank deposits, CFTC regulation, commodity for future delivery, commodity trading advisors, common control, CTAs, dually-registered investment advisers, duplicative registration, exempt reporting advisers, foreign private advisers, Form ADV, Form MA, guaranteed investment contracts, investment advisers, investment advisory services, investment strategies, Kleinwort Benson Investment Management Limited, mid-sized adviser, multi-jurisdictional advisory firms, municipal advisor, municipal advisors, municipal advisory activities, municipal derivatives, municipal escrow investments, municipal financial products, municipal securities, Murray Johnstone Holdings Limited, no-action letters, option, participating affiliate agreements, pay to play rule, pooled investment vehicle, pooled investment vehicles, pools of assets, primary investors, private adviser exemption, private fund advisors, private fund managers, registered advisor, registered broker-dealer, registered CTAs, registered investment advisers, regular oversight, regulated persons, Royal Bank of Canada, SEC, SEC No-Action Letter, SEC oversight, SEC regulation, SEC resources, SEC-registered entities, Securities and Exchange Commission, securities futures product, Security-Based Swap, self-regulatory entity, solicitation, state entity, state securities commission, state-registered investment advisors, third-party solicitor, transition period for registration, Uniao de Banco de Brasileiros, venture capital funds,

Comment Letter Responding to SECs Proposed Exemptions for Advisers to Venture Capital Funds, Private Fund Advisers With Less Than $150 Million in Assets Under Management, and Foreign Private Advisers01.24.11


MFA submitted a comment letter to the SEC in response to the SECs proposal Exemptions for Advisers to Venture Capital […]

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Topics: 1983 SEC No-Act. LEXIS 2576 26 S.E.C. 426, ABA Subcommittee on Private Investment Entities, affiliate letters, affiliated entities, Affiliated Person, AMRO Bank N.V., assets under management, Associated Persons, CFTC, Commodity Futures Trading Commission, commodity trading advisor, commodity trading advisors, Compliance and Management Structures, Control, CTA, de minimis exemption, Domestic, Equity Security, Exemptions, Exemptions Release, Factual Representations, Fair Value, Foreign Advisers and Subadvisers, foreign private advisers, Form ADV, Full Regulatory Access, general partner, Gross Assets Calculation, Hedge Fund Adviser Registration Rules, Independent Verification of Assets Requirement, Instrument, Investment Adviser Industry, investor, Kleinwort Benson Investment Management Limited, Limited Liability Company, Limited Partner, limited partnership, Master-Feeder Structure, Mercury Asset Management Plc., Multi-Jurisdicational Advisory Firms, no-action letters, Nominal Capital Account, Non-Control, Non-Registered Adviser, Non-U.S. Activities, Non-U.S. Investment Advisory Firms, Non-U.S. Law, Outstanding Voting Securities, oversight, Participating Affiliate, Peavey Commodity Futures Fund, pooled investment vehicle, private fund, Private Fund Advisers, Private Fund Registration, prudential regulators, Question VI.11, Record Owner, Redemption, Registered and Non-Registered Entities, Regulatory Assets, regulatory assets under management, Regulatory Authority, Royal Bank of Canada, SEC, SEC No-Action Letter, Secretary of the Treasury, Securities and Exchange Commission, Securities-Related Advice, Security-Based Swap, separate account structure, Side-by-Side Structure, Single Investor Private Funds, Specialized Expertise, Specialized Feeder, Staff Responses to Questions About the Custody Rule, Statutory Exemption, Subadvisers, Subsidiary Advisers, systemic risk, Tonopah Mining Co. of Nevada, total return swap, Transparency Rights, U.S. law, Unio de Banco de Brasileiros S.A., valuation methodology, venture capital funds, Voting Rights,
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