MFA Comment Letters

Topic: threshold

Comment Letter on Joint Release Regarding Reporting by Investment Advisors to Private Funds and Certain Commodity Pool Operators and Commodity Trading Advisors on Form PF04.08.11


MFA filed a comment letter with the SEC and CFTC in response to their joint proposal to require private fund […]

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Topics: absolute return strategies aggregate borrowings, aggregate gross asset value, alternative methodology, asset-backed securities, assets under management, audited financial statements, balance sheet value, beneficial owners, bespoke contracts, Bloomberg, borrowing arrangements, CCPs, CDS, CDX, central clearing counterparties, CFTC, clause (iii), collateral, collateral practices, commodity pool operators, commodity trading advisors, confidentiality of information, confidentiality protections, corporate bonds, Council and Office of Financial Research, counterparty exposures, CR01, creditor, currency rates, CUSIP number, DCMs, de minimis, debt securities, default rates, delta adjusted, direct clearing members, direct investments, distressed debt, Dodd-Frank Act, duration, DV01, equity derivatives, equity exposure, equity prices, FCMs, Federal Reserve System, Financial Accounting Standards Board, Financial Stability Oversight Council, five-year option, fixed advisory fees, foreign currency contracts, foreign exchange derivatives, Form 10-K, Form 10-Q, Form 13F, Form ADV, Form CPO, Form CTA-PR, Form PF, Form PF question 36, form PF questions 28 and 35, Form PQR, FSA, funds of funds, futures commission merchants, futures contracts, GAAP, generally accepted accounting principles, global regulators, GMV, gross asset value, hedge fund assets under management, hedge fund defaults, illiquid assets, inadvertent disclosure, inception class, individual certification, interconnectedness, interest rates, interpretive guidance, Investment Adviser Registration Depository, investment advisers, investment expenses, large private fund manager, lending institutions, Level 2 inputs, Level 3 inputs, leverage, liquidity management, liquidity risk, LMV, loan commitments, long positions, managed futures, margin requirements, market noise, market participants, market value, master agreement, master-feeder, maturity brackets, maturity mismatch, NAV, net asset value, net assets under management, net borrowings, non-bank financial companies, non-rated issues, notional amount, notional value of derivatives, offsetting exposure, OFR, operational capabilities, operational efficiency, other quantitative strategies, overcounting, parallel funds, parallel managed accounts, performance fees, portfolio management, prime brokers, private equity, private fund managers, private funds, privately issued convertible bonds, proposed reporting thresholds, proprietary information, proprietary methodology, public companies, qualifying fund, record owners, recordkeeping requirements, regulatory assets under management, regulatory scrutiny, rehypothecated initial margin, reporting period, repos, risk capital allocation, risk methodology, Schedule 13G, SEC, section 404, semi-annual reporting, sensitivity analyses, short borrowing, short positions, short term high quality corporate debt, short-term interest rate, short-term market fluctuations, side pocket arrangement, SMV, statistical arbitrage-equity, strategy exposure, swap contracts, synthetic borrowing, systemic risk, systemically significant, targeted requests, ten-year option, the Fed, threshold, threshold for enhanced performance, tiered reporting system, trading and investment strategies, tri-party collateral accounts, turnover rate, UK Financial Services Authority, unaffiliated third party sources, uncommitted lines of credit, undercounting, valuation methodology, Value at Risk, VaR, variation margin,

Comment Letter Responding to SEC’s Proposal to Implement Amendments to the Advisers Act Contained in Title IV of the Dodd-Frank Act01.24.11


MFA submitted a comment letter todayto the SEC on its proposal to implement amendments to the Advisers Act contained in […]

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Topics: $1 Billion 11 and 12, 13 and 29, 15, 17, 5.D and 5.F, assets, assets under management, Bank of America-Merrill Lynch, banks, Basel Committee on Banking Supervision, beneficial owners, broker dealers, collateral, Columbia University, Commission on Form ADV, Committee on Financial Services, Compensation Structure, Compliance Risks, counterparties, Credit Unions, De Minimis Amount, Debt-to-Equity, Definition, Depository Institutions, Difficult-to-Value Assets, Duplicative Filing, effective date, Effective Date of Title IV, equity owner, European Central Bank, Excessive Compensation, Exemption, Fair Valu Hierarchy, Fair Value Methodology, Family Accounts, Form ADV, Form ADV Part 1A, Form ADV-T, FSA, GAAP, generally accepted accounting principles, Grandfathering Provisions, gross assets, Hearing on Industry Perspectives on the Obama Administration's Financial Regulatory Reform Proposals, hedge fund industry, Hedge Fund Manager Registration Rul, hedge fund managers, hedge funds, IARD, IARD System, Incentive-Based, Incentive-Based Compensation Arrangements, Income Thresholds, Instruction 5.b., Instruction 5.b(4), International Accounting Standards, investment adviser, Investment Adviser Registration Depository, Investment Management, Investor Protection Benefits, leverage, Leverage Ratios, Mid-Sized Manager, Mid-Sized Managers, National Securities Exchanges, net assets, NSMIA, Part 1A, performance fee, pooled investment vehicle, Portfolios, private adviser exemption, Private Fund Information, private fund managers, Proposed Instruction 1.b., Proposed Items 14, Proposed Items 5.A, Proprietary Accounts, Proprietary Accounts of the Manager, proprietary information, public disclosure, qualified client standard, qualified purchaser, registration, Registration Process, registration requirements, regulatory assets under management, Richard H. Baker, Schedule D, SEC, SEC-registered investment advisers, SEC-Registered Managers, SEC's Contract, Section 7.B.1, Securities and Exchange Commission, Securities Commissioner, state securities commission, Substantive Provision, systemic risk, Taxpayer Money, The Turner Review, threshold, Threshold of $25 Million, Tier 1 Financial Holding Company, transitional relief, U.S. House of Representatives, Unit-Linked Life Insurance, Unregistered Managers, Valuation Information, valuation methodology, venture capital funds, Wealth and Income Requirements,

MFA Comments to SEC Regarding Proposals to Revise Limited Offering Exemptions in Regulation D10.19.07


MFA submits a comment letter to the SEC regarding their proposals to revise the limited offering exemptions in Regulation D.

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Topics: 20% beneficial owner Accerdited Investor, accounting officers, accredited investor, accredited natural person, affiliated issuer, attorneys, bad actor disqualification provisions, beneficiaries, blue sky filing, brokers, capital, capital formation, cease and desist, committed capital, compliance, deferred compensation, director, Disqualification Provisions, Division of Enforcement, dollar-amount thresholds, dollar-amount threshols, due diligence, economic efficiency, equity owners, executive officer, federal regulations, financial eligibility standard, financial sophistication standards, flexibility, Form D, Fraud, fund principals, Future Inflation Adjustment, General Advertising, general partner, General Solicitation, global alternative investment industry, grandfather provision, Grandfathered, hedge funds, higher dollar-amount thresholds, implications of the growth of hedge funds, inflation, inflation adjustments, Interation Safe Harbor, investments tests, investor, Investor Protection, Investor relations professionals, Issuer, issuers, joint income thresholds, Joint Investments, knowledgeable employees, limited announcement, Limited Coffering Exemptions, managed futures funds, managing member, Manner of Offering, marital assets, natural persons, net worth, offering, Offerings, offers, Office of Economic Analysis, operational, policymaker, pooled investment fund, pooled investment funds, pooled investment vehicles, predecessor, primary beneficiary, private placement, private placement offerings, Private Pooled Investment Vehicle Release, privated pools of captial, promoter, Public Offerings, qualification, qualified client, Qualified Client Definition, qualified purchaser, Qualified Purchaser Definition, qualifies purchasers, recdivism, research analysts, retention tool, risk, risk/return, sale limitations, SEC, securities, Securities and Exchange Commission, senior financial, Sophisticated Investor Standards, sophisticated investors, sotck, start up company, subscription agent, Subscription Agreement, threshold, traders, traders of a fund affiliate, transaction costs, transactions, transparency, Trust Grantors, Trustees, U.S. Congress, United States,
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