kaal:claim:2447306-004

If advisers' allegations that Form PF disclosures cannot be answered other than by guessing are correct, then the SEC's capacity to evaluate the data is compromised, and regulation built on incomplete and misleading data will itself be questionable.

If these allegations should be true, the SEC's ability to evaluate and assess the data could be compromised. The use of incomplete and misleading data could lead to the development of questionable policies and regulations applicable to the private fund industry.

Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014), I. Introduction, p. 5
https://ssrn.com/abstract=2447306 · source PDF

Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306

• conditional on the accuracy of anecdotal reports from advisers

mechanismsupport: arguedfailure: garbage-in-policy-outfamily: data-quality-and-comparabilityprivate-fundssystemic-riskrisk-and-incentivessecurities-law

• 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...
• extends kaal:claim:2348463-022 Form PF disclosures have not been standardized, and anecdotal evidence indicates that the SEC and the FSOC may...
• extends kaal:claim:2348463-007 The SEC has not standardized the disclosures required in Form PF, and there is evidence that Form PF requireme...
• supported_by kaal:claim:2470008-023 Advisers take different approaches and make different assumptions when completing Form PF, which the SEC ident...
• 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...
• 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...
• extends kaal:claim:2150377-040 If advisers sanitize their Form ADV and Form PF filings, the disclosures become less useful for FSOC and SEC e...
• extended_by kaal:claim:2470008-033 Because several core Form PF questions feeding the FSOC's stage one threshold screen are themselves defective,...

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