kaal:claim:2150377-040

If advisers sanitize their Form ADV and Form PF filings, the disclosures become less useful for FSOC and SEC evaluation and undermine the very determination of systemic risk posed by private funds that the reporting regime was built to enable.

Although the level of sanitizing of disclosures cannot be verified, sanitized disclosures could be less useful for FSCO and SEC evaluation and their determination of the systemic risk posed by private funds.

Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012), B. Private Fund Policy and Future Research
https://ssrn.com/abstract=2150377 · source PDF

Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377

• to the extent disclosures are in fact sanitized, which the Author states cannot be verified

failuresupport: speculativefailure: sanitized-disclosure-defeats-systemic-risk-monitoringfamily: disclosure-ineffectivenesssystemic-riskrisk-and-incentivesdisclosureprivate-funds

• restated_by kaal:claim:2998097-014 Because advisers and third party service providers can flatten out and sanitize the information disclosed in F...
• extended_by kaal:claim:2470008-002 Accuracy and consistency problems in the SEC's private fund data collection can impair the FSOC's ability to e...
• extended_by kaal:claim:2447306-004 If advisers' allegations that Form PF disclosures cannot be answered other than by guessing are correct, then ...

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