kaal:claim:2389416-029

The Dodd-Frank Act registration threshold creates incentives strong enough that some advisers opt out of registration and disclosure by strategically changing their AUM size to stay below $150 million.

It is possible that the enactment of the Dodd-Frank Act introduces incentives that are powerful enough to cause some hedge fund advisers to opt out of Dodd-Frank Act registration and disclosure through a strategic change of AUM size.

Wulf A. Kaal, Barbara Luppi, Sandra Paterlini, Did the Dodd-Frank Act Impact Hedge Fund Performance (2014), 5.2.2. Strategic Subsample
https://ssrn.com/abstract=2389416 · source PDF

Wulf A. Kaal, Barbara Luppi, Sandra Paterlini, Did the Dodd-Frank Act Impact Hedge Fund Performance (2014). SSRN: https://ssrn.com/abstract=2389416

• advisers with AUM floating around the $150 million threshold

mechanismsupport: arguedfailure: Threshold gaming to avoid registrationfamily: regulatory-arbitrageregulatory-failurerisk-and-incentives

• supports kaal:claim:2150377-028 Where the Form PF quarterly reporting threshold does influence behavior, it distorts fund size downward: a maj...
• supports kaal:claim:2150377-008 Because Title IV's registration exemptions are broad enough to threaten the rule they qualify, the Dodd-Frank ...

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