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MFA Comment Letters

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Topic: third country managers

MFA Responds to HM Treasury’s Discussion Paper on AIFMD05.04.12


MFA responded to HM Treasury’s discussion paper “Policy Options for Implementing the Alternative Investment Fund Managers Directive” (AIFMD).  In our […]

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Topics: HM Treasury Alternative Investment Fund Managers Directive, AIFMD, non-EU AIFM, disproportionate regulatory burden, collective investment scheme, third country funds, UK private placement regime, AIFs, investors, sub-threshold AIFMs, UCITS, self-managed AIF, third country AIFM, MiFID, unregulated collective investment schemes, EU Member State, investor protection regime, venture capital funds, social investment funds, domestic fund, marketing, retail investors, Regulators, United States Congress, sales of private funds, third country managers,

MFA Response to FSA Discussion Paper on Implementation of the AIFMD03.23.12


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Topics: FSA Discussion Paper "Implementation of the Alternative Investment Fund Managers Directive" Financial Services Authority, FSA, Alternative Investment Fund Managers Directive, AIFMD, non-EU AIFM, Member State competent authorities, letter-box entity, MiFID, MiFID firm, AIFMD firm, retail customers, professional investors, remuneration provisions, CRD3 framework, functional and hierarchal independence, risk management, internationally coordinated approach to reporting, European Securities and Markets Authority, ESMA, single AIFM, family relationship, family investment vehicle, UK AIFM, preferential treatment, side letters, retail consumers, FSA Principles for Business, FCA, UCITS Directive, retail investors, EU Passport, FCA Approach Document, conflicts of interest, SYSC 10 of the FSA Handbook, remuneration guidelines, MiFID portfolio managers, tier 4 firm, FSA Remuneration Code, compliance function, audit function, proportionality principle, regulatory requirements, regulatory risks, chief compliance officer, functional and hierarchical separation, portfolio management, portfolio management personnel, interest alignment, qualitative risk limit, UCITS investors, institutional investors, leverage, NAV, third country, Final Advice on the AIFMD, third country managers, capital requirements, PII requirements, IPRU (INV), professional indemnity insurance, professional negligence, internally managed AIF, CAD-defined terms, valuation procedures, external valuer, net asset value, limited partnership, hedge funds, NAV per share, liquidity requirements, redemption terms, less than fully invested, risk/return profile, net assets under management, investor capital, Value at Risk, VaR methodology, European Central Bank, foreign exchange, interest rate risk, EUR denominated bonds, portfolio risk, hedging arragements, CESR Guidelines on Risk Management and the Calculation of Global Exposure and Coutnerparty Risk for UCITS, CDS, Advanced Method, QIS disclosure requirements, prime brokers, exchanges, swap data warehouses, Dodd-Frank Act, Securities and Exchange Commission, SEC, Form PF, proprietary business information, depositary, unregulated CIS, segregated account, valuation oversight duties, depositary liability, marketing, reverse solicitation process, MiFID investment services, private placement, public offers,

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 […]

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Topics: Committee of European Securities Regulators European Securities and Markets Authority, ESMA, AIFMD, third country managers, EU investors, European Commission, Dual National Private Placement, EU Passport Regimes, Third Country Fund Managers, G-20, Non-EU Alternative Investment Fund Managers, EU Sub-Managers, assets under management, alternative investment funds, AIFs, Standard of Liability, hedge funds, investment strategies, Underlying Assets, redemption policy, Sub-Management, marketing, research, registered investment adviser, U.S. Securities Exchange Commission, SEC, Primary Manager, contractual relationship, Investment Management Agreement, gross assets, net assets, Trade Secrets, proprietary, Confidential Information, Private Investments Funds, Reverse Engineered, prime brokers, exchanges, swap data warehouses, U.K. Financial Services Authority, FSA, Capital Requirements Directive, CRD III, leverage, financial counterparties, broker dealers, risk monitoring, counterparty financial institutions, substantial basis, systemic risk, off-balance liabilities, overnight borrowing, term borrowings, liquidity rights, cooperation agreements, proprietary information, confidentiality, Double Counting, member state of reference, Legal Representative, Commercial Contract, Subscription Agreement,
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