kaal:claim:2348463-007

The SEC has not standardized the disclosures required in Form PF, and there is evidence that Form PF requirements rest on an inconsistent use of industry terms, which can in turn produce inconsistent and contradictory data reporting.

The SEC has not yet standardized the required disclosures in Form PF and there is some evidence that the disclosure requirements in Form PF are based on an inconsistent use of industry terms which may in turn result in inconsistent and perhaps contradictory data reporting.

Wulf A. Kaal, Hedge Funds’ Systemic Risk Disclosures in Bankruptcy (2013), INTRODUCTION, p. 7
https://ssrn.com/abstract=2348463 · source PDF

Wulf A. Kaal, Hedge Funds’ Systemic Risk Disclosures in Bankruptcy (2013). SSRN: https://ssrn.com/abstract=2348463

• Form PF as promulgated and in effect at the time of writing

failuresupport: evidencedfailure: inconsistent industry terminology in Form PFfamily: data-quality-and-comparabilityprivate-fundssystemic-riskdisclosurerisk-and-incentives

• extended_by kaal:claim:2470008-026 Form PF data quality and utility are likely to improve over time as filers grow familiar with the form's requi...
• extended_by kaal:claim:2447306-004 If advisers' allegations that Form PF disclosures cannot be answered other than by guessing are correct, then ...
• supported_by kaal:claim:2470008-022 The SEC itself reports that the consistency of investment advisers' responses on Form PF is not ensured and ma...
• extended_by kaal:claim:2470008-037 If the FSOC relies on inaccurate Form PF data in its systemic risk assessment, its work on private funds may i...
• extended_by kaal:claim:2470008-025 Expanding the uses of Form PF data remains difficult so long as there is insufficient confidence in the accura...
• generalizes kaal:claim:2447306-037 Form PF fund performance metrics are not accurate or comparable across filers, because reporting entities empl...
• generalizes kaal:claim:2470008-031 The interpretation Form PF demands generated particular concern among filers about the definition of counterpa...
• restated_by kaal:claim:2714974-012 The most pressing problem with Form PF identified by the majority of SEC registered hedge fund advisers is not...
• supports kaal:claim:2150377-039 Mandatory reporting does not guarantee informative reporting: anecdotal evidence indicates that advisers can p...
• extended_by kaal:claim:2470008-003 Prior studies and anecdotal evidence indicate that the data collection mandated by Form PF could itself create...
• supported_by kaal:claim:2470008-024 The SEC's initial analysis of Form PF data turned up anomalies attributed to filer error, which prompted SEC c...

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