MFA Comment Letters

Topic: United States

MFA Submits List of Priorities to CFTC Chairman Massad and Commissioners07.30.14


MFA submitted letters to Timothy Massad, the newly confirmed Chairman of the Commodity Futures Trading Commission (CFTC), along with the […]

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Topics: aggregation AIMA, alpha swap, alternative investment funds, Alternative Investment Management Association, alternative investment strategies, anonymity, Asset Management Group of the Securities Industry and Financial Markets Association, assets under management, AUM, Bankruptcy Code, benchmark contracts, bespoke swaps, beta swap, board of directors, British Virgin Islands Financial Services Commission, burdensome, buy-side, cash-settled contracts, Cayman Islands, Cayman Islands Monetary Authority, CCP, central clearing, central counterparties, CFTC, chilling effect, cleared swaps, collateral, Committee of Payment and Settlement Systems, Commodity Futures Trading Commission, commodity interests, Commodity Markets Council, commodity pool, commodity pool operators, commodity trading advisors, compliance, corporations, CPO, CPO delegation, Cross-Border, CTA, custody rules, customer collateral, customer protection, DCM, DCO, Dealer, dealer-to-customer platforms, derivatives clearing organization, designated contract markets, Division of Market Oversight, Division of Swap Dealer and Intermediary Oversight, Dodd-Frank Act, due diligence, EFRPs, EMIR, EU, European Commission, European Union, exchange for related position, execution, exemptive relief, FCM, FCM counterparty, Financial Conduct Authority, financial counterparty, Financial Stability Board, floor brokers, Form CPO-PQR, Form CTA-PR, Form PF, Form PQR, FSB, Full Physical Segregation, fund of funds, futures commission merchant, GAAP, gamma swap, general partner, generally accepted accounting principles, gold, haircuts, harmonization, hedge fund, hedgers, Hong Kong, illiquid assets, initial margin, insolvency, inter-dealer market, interest rate markets, International Organization of Securities Commissions, International Swaps and Derivatives Association, introducing broker, invoice spreads, IOSCO, ISDA, J. Christopher Giancarlo, JOBS Act, legal segregation with operation commingling, limited liability companies, limited partnership, liquidity, loss allocation, LSOC, made available for trading, Major Swap Participant, mandatory clearing, Mark Wetjen, market infrastructures, market participant, master agreement, MAT, MF Global Inc., MSPs, National Futures Association, natural gas, NFA, no-action relief, Obama Administration, OTC derivatives, OTC Derivatives Regulators Group, owned entities, package transactions, passive ownership, Peregrine Financial Group, physically settled, Policy Makers, position limits, President Obama, price discovery, private equity fund, private funds, private investment funds, private investment vehicles, privately offered commodity pools, proprietary trading tools, public investment fund, quarterly account statements, real estate investment trust, recordkeeping requirements, registered investment adviser, regulation, regulatory framework, regulatory requirements, risk management, Scott O'Malia, SDR, SEC, Securities and Exchange Commission, Securities and Futures Commission, SEF, segregated account, service providers, Sharon Bowen, short, SIFMA AMG, silver, speculation, spot-month position limits, straight-through processing, swap butterflies, swap curves, swap data reporting, swap data repository, swap dealer, swap execution facilities, swaps, swaptions, systemic risk, temporary interim relief, third country, Timothy Massad, trading privileges, transparency, Trust, U.S. Commodity Futures Trading Commission v. Peregrine Financial Group Inc. and Russel R. Wasendorf, U.S. Congress, U.S. Department of the Treasury, U.S. person, United States, variation margin, Vincent A. McGonagle,

MFA Letter to ESAs on EMIR Risk Mitigation Regulatory Technical Standards07.14.14


MFA submitted a comment letter to the European Supervisory Authorities (ESAs) on their joint consultation paper on “Draft regulatory technical […]

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Topics: AIMA alternative investment funds, Alternative Investment Management Association, base currency, Basel Committee for Banking Supervision, Canada, Cayman Islands, clearing threshold, collateral, collateral currency, concentration limits, consultation paper, Council of the European Union, counterparties, counterparty credit risk, dispute resolution procedures, documentation, duplicative regulation, efficiency, EMIR, equivalence, ESMA, European Banking Authority, European Commission, European Insurance and Occupational Pension Authority, European Market Infrastructure Regulation, European Parliament, European Securities and Markets Authority, European Supervisory Authorities, financial counterparties, France, G7, Germany, haircuts, harmonization, in-scope entity, Individual Segregation, initial margin, International Organization of Securities Commissions, International Swaps and Derivatives Association, IOSCO, ISDA, Italy, Japan, legal opinion, liquidation, liquidity, mandatory margin requirements, margin, market participants, minimum notional threshold, netting, non-financial counterparty, OTC derivatives market, proportionality principle, regulatory arbitrage, regulatory requirements, regulatory technical standards, securities, segregation, settlement currency, settlement period, substituted compliance, systemic risk, third country, third party custodian, trade repositories, trading costs, transparency, uncleared derivative, United Kingdom, United States, US Treasuries, variation margin, verification requirement,

MFA Submits Comment Letter in Response to Basel-IOSCO’s Consultative Document on Margin Requirements for Non-Cleared Derivatives09.28.12


MFA submitted a comment letter to the Working Group on Margining Requirements (WGMR) of the Basel Committee on Banking Supervision […]

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Topics: asset classes Basel Committee on Banking Supervision, best practices, bilateral exchange, bilateral exchange of variation margin, buy-side firms, CCP, CDS, CDS spreads, central clearing, central counterparty, CFTC, cleared derivatives, clearing, clearing house, commodities, Commodity Futures Trading Commission, concentration limits, correlated financial instruments, cost mitigation, credit, credit default swap, credit risk, cross-product master netting agreements, currency, custodian accounts, delta, Denominated in G7 Currencies, derivatives, derivatives markets, diversification, Dodd-Frank Act, eligible collateral, equities, EU, Eurodollar futures, European Union, financial instruments, foreign exchange, forwards, G7, haircuts, harmonization, hedge, hedge funds, hedged portfolios, implementation timeline, initial margin, interest rates, International Organization of Securities Commissions, International Swaps and Derivatives Association, IOSCO, ISDA, liquidation, liquidity, liquidity characteristics, liquidity costs, liquidity mechanism, major swap participants, mandatory clearing, margin, margin requirements, margin threshold, margining, market advantage, market infrastructures, market liquidity, market participants, market practices, market value, minimum transfer amount, MTA, mutually offsetting transactions, netting, non-centrally cleared derivatives transactions, non-cleared derivatives, non-cleared interest rate swaps, non-compliance, notional value, novating parties, novation, novation arrangements, over-collateralization, party stepping in, party stepping out, phase-in period, portfolio margining, Portfolios, prudential regulators, prudentially regulated financial counterparties, quantitative impact study, re-hypothecation, Regulators, regulatory arbitrage, regulatory authorities, remaining party, replacement transaction, repurchase agreements, risk characteristics, risk management, risk offsets, risk profile, risk/reward profile, segregated account, segregation, SIFI, standard practice, swap dealers, swaps, systemic importance, systemic risk, systemic risk level, systemically important, systemically important non-financial firm, third-party segregation, transparency, two-way margining, U.S. Treasury futures, uniformity, United States, unlevel playing field, unsecured credit extension, variation margin, Working Group on Margining Requirements,

MFA Submits Comments to USTR on Mexican Bankruptcy Law for Trade Negotiations09.04.12


MFA submitted comments to the U.S. Trade Representative (“USTR”) raising concerns with the Mexican Business Reorganization Act as demonstrated by […]

MFA Petitions the CFTC to Exclude Certain Employee Pools from the Definition of “Pool”08.30.12


MFA petitioned the CFTC to provide an exclusion from the definition of commodity “pool” for certain internally owned entities, including […]

MFA Submits Letter to ESMA on Straight-Through-Processing08.05.12


On August 5, MFA submitted a comment letter to the European Securities and Markets Authority (ESMA) to advocate for the […]

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Topics: aggregate limit Allocations, alternative liquidity providers, anti-competitive effects, anti-competitive restrictions, bid-ask spread, bilateral credit agreement, bilateral derivatives transactions, bilateral market, bilateral master agreements, bilateral risk management, block transactions, breakage, bundled trade, CCP, CCP Requirements Task Force, CDS, central counterparty, central limit order books, CFTC, Chicago mercantile exchange, Christopher Seagon v. Deko Marty Belgium NV, clearing, clearing acceptance process, clearing agreement, clearing member, clearing obligation, clearinghouse, CME, Commission v. Council ERTA, Commodity Futures Trading Commission, competition, competitive liquidity, Continental Cans, cost-benefit analysis, Council of the European Union, counterparty credit risk, Court of Justice of the European Union, credit default swap, credit intermediation, credit limit, credit limit order bookc, credit limits, credit risk, customer clearing documentation, DCM, DCO, dealer-to-customer platforms, dealer-to-dealer clearing, dealers, delegated acts, derivatives, derivatives clearing organization, derivatives markets, derivatives transactions, Designated Contract Market, designation notice, direct clearing members, directive, documentation, Dodd-Frank Act, due diligence, efficiency, electronic trading, EMIR, endowments, energy derivatives, ESMA, ESMA Task Forces, EU, EU Member State, European Commission, European Parliament, European Securities and Markets Authority, European Union, executing counterparty, execution, execution platform, FIA, financial stability, Financial Stability Board, financial system, FSB, futures, Futures Industry Association, futures market, ICE Clear Credit LLC, ICE energy swaps, institutional investors, interconnectedness, interest rate swap, international harmonization of regulations, International Swaps and Dealers Association, investment managers, ISDA, latency, LCH Clearnet, limit check, liquidity, liquidity fragmentation, Liquidity Providers, Major Swap Participant, Managed Funds Association, mandatory clearing, market access, market participants, matched transactions, operational market processes, operational risk, OTC derivatives, OTC Derivatives Task Force, OTC derivatives transactions, over-the-counter derivatives, pension fund, real economy, real-time acceptance, real-time processing, regulatory technical standards, risk, risk management, risk-based, SEF, settlement, straight-through processing, swap dealer, Swap Execution Facility, systemic risk, technical standards, trade repositories, Trade Repositories Task Force, trading desk, trading venues, transaction capture facility, transparency, trilateral clearing agreements, trilateral documentation, underlying clients, United States, voice execution, volatility,

MFA Submits Letter to Department fo the Treasury Regarding Review by the Treasury Department of the Regulatory Structure Associated with Financial Institutions11.21.07


MFA submits letter to the U.S. Department of the Treasury in response to its request for recommendations on how to […]

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Topics: adequate disclosure Asian Countries, Australia, BaFin, bonds, business models, capital raising process, CFTC, collateral management stystems, collective investment vehicles, commercial, Commodity Futures Trading Commission, commodity pool operator, commodity pool operators, common stock, competitiveness concerns, compliance, conduct-of-business, conflicting regulatory edicts, Congress, costs, counterparites, cross-recognition efficiencies, crude oil, currency options template, customer protections, Department of the Treasury, derivatives, derivatives clearing organizations, Disclosure, duplicative systems, Europe, exchange, exchanges, fair prices, Federal Energy Regulatory Commission, federal government, FERC, Financial Industry Regulatory Authority, financial institutions, financial integrity systems, financial products, Financial Services Action Plan, Financial Services Roundtable, FINRA, flexibility, foreign markets, Fraud, fund of funds, funds, futures, futures brokerage commission payments, futures contracts, futures exchange, G-8 finance ministers and deputies, global alternative investment industry, gold, hedge fund investors, hedge funds, hedging, Henry Paulson, higher prices, intemediary brokerage firms, intermediaries, International Organization of Securities Commissions (IOSCO), international organizations, international portfolio valuation principles, international regulatory standards, Investor Protection, Japan's Financial Services Agency, liquid trading markets, local law enforcement, managed futures funds, margin area, margin levels, market and financial integrity, Market Particpants, market price transparency, marketplace, mutual, National Futures Association, natural gas, natural gas futures price manipulation, net capital, net long, Netherlands, NFA, optimal regulatory structure, options contracts, options trading, ownership interest, peer-to-peer guidance for hedge fund managers, Policy Makers, pool offerings, portfolio margining, Portfolios, President's Working Group on Financial Markets, principles-based approach, private pools of capital, private sector self-regulation, private transactions, prudential safety, public interest, public interest goals, public managed futures fund offerings, PWG, regions, regulation of intermediaries, regulatory framework, regulatory oversight, Regulatory Structure, retail customers, retail foreign exchange (FX), risk management, risk-based performance bond system, rules-based approach, safe harbor, SEC, securities, Securities and Exchange Commission, security futures, short, Sound Practices for Hedge Fund Managers, soundness regulation, state regulators, state securities regulators, statutory core principles, stock index, stock price, stock world, substantial inefficiency, tired system of regulation, trading business activties, trading platforms, transactions, twin peaks model, U.S. capital market competitiveness, underlying asset, uniform set of basic principles of regulation, United Kingdom's Financial Services Authority (FSA), United States, unwarranted costs, valuation, wheat, wholesale,

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,

MFA Comments to IOSCO’s Call for Views on Issues That Could Be Addressed by IOSCO on Funds of Hedge Funds08.03.07


MFA submits comments in response to IOSCO’s “Call for Views on Issues that Could Be Addressed by IOSCO on Funds […]

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Topics: a 5% annual return absolute return strategies, accredited investors, accrual method of accounting, acquired fund fees, administrators, advertisement, advertising rules, adviser, adviser operations, advisory contract, advisory contracts, affiliated broker, Affiliated Person, agency transactions, an oath or affirmation, annual financial statements, Annual Report, annual self-assessment, asset coverage, assets, audit, audit committee financial expert, audit-related, bank, bank custodians, board members, borrowed funds, borrowings, breaches of fiduciary duty, break-even chart, broker dealers, broker-dealer, business background, capital stock, cash purchase plan fees, CFTC, cherry picking, chief compliance officer, closed-end investment companies, codes of ethics, committee structure, commodities, Commodity Futures Trading Commission, commodity pool operator, Commodity Pools, common shares, Company Act Disclosure Requirements, Company Act FOHFs, Company Act Registration, company obligations, compensation, compliance, compliance examinations, compliance policies and procedures, conflicts of interest, Congress, counsel, counterparty creditworthiness, CPO, custodians, custody, Department of the Treasury, derivative instruments, derivative market practices, directed brokerage arrangements, Disclosure, disclosure documents, disclosure requirements, diversification, dividend reinvestment, dividends, executive session, Exemption, expenses, family of investment companies, Federal Reserve, Federal Securities Laws, fee table, fees, Financial Industry Regulatroy Authority, financial reporting to investors, FINRA, fiscal period, FOHF Report, for cause examinations, Form N-2, Form N-CSR, Form N-SAR, fraudulent or manipulative practices, Full Part 4 CPOs, Full Part 4 Funds, fund of funds, futures brokers, futures professionals, General Solicitation, global alternative investment industry, glossaries, hedge fund industry, hedge funds, high net worth requirements, high risk, independent public accountant, independent registered public accounting firm, initial investment, initial investment requirements, interest payments, interested persons, international advisory and government bodies, investment companies, investment company, Investor Protection, Investor Protection Issues, Investor Suitability, investor's capital contribution, IOSCO, IOSCO Report, IOSCO Technical Committe Standing Committee on Investment Management, IOSCO Technical Committee, legends, leverage, liability, liquidation, liquidity, major dealers, managed futures funds, management agreements, management fees, Manner of Offering, margin obligations, mass mailings, material fact, material pending legal proceedings, MFA's Sound Practices for Hedge Fund Managers, mutual, NASD, National Futures Association, natural person, net asset value, net assets, net worth, New York Stock Exchange, NFA, NFA Notice I-07-25, non-voting interests, offering, offering disclosure regime, offering price, offering prive, open-end investment companies, outstanding voting, ownership of shares, performance fees, periodic statements, periodic tender offers, personal securities transactions, Plain English Principles, Plain English Requirements, policymakers, Portfolio Holdings, portfolio managers, principal executive, principal financial officers, principal transactions, private offering exemption, private sector, private sector initiatives, promotional material, prospective investors, prospectus, proxy voting, Public Offering, public sector, public trading market, qualified clients, rask factors, real estate, record keeping requirements, recordkeeping requirements, registration statements, regulatory regime, retail funds, Retail investment, retail investors, retail investors' increased investment in FOHF's, retail market, risk factors, safe harbor, sales loads, SEC, securities, Securities and Exchange Commission, Securities Exchange Board of India, securities transactions, Senior officer code of ethics, senior securities, share repurchases, shareholder approval, shareholders, shares, soft dollar, state agencies, state securities regulators, statement of additional information, Subscription Agreement, sweep examinations, table of contents, tansferability and redemption rights, tax, tax consequences, tax status, technical terms, total annual expenses, total return, transaction fees, transactions, U.S. Funds of Hedge Funds, U.S. GAAP, U.S. generally acceped accounting principles, unaudited semi-annual reports, underlying fraud, underwriters, undistributed profits, United Kingdom's Financial Services Authority, United States, verbatim risk of loss disclosure statements, volatility, voting,
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