kaal:claim:1806252-033

Requiring advisers to adopt written policies to prevent and detect securities law violations presumes those violations are foreseeable, yet because Dodd-Frank substantially changed securities law, the foreseeability of potential violations is itself further curtailed.

But because securities law has been substantially changed under the Dodd—Frank Act, the foreseeability of potential violations could be further curtailed.

Kaal, Hedge Fund Regulation Via Basel III (2011), III.2.c.4 Cost of Compliance, p. 44
https://ssrn.com/abstract=1806252 · source PDF

Kaal, Hedge Fund Regulation Via Basel III (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1806252

• PFIARA requires written compliance policies just after Dodd-Frank changed the underlying law

failuresupport: arguedfailure: unforeseeable-compliance-targetfamily: othercompliance

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