kaal:claim:2447306-024

Form PF's definition of leverage is overinclusive: respondents reported that it is inappropriately constructed and sweeps in funds that use neither leverage nor derivative securities.

Source quote, verbatim

Several respondents suggested that the definition of leverage is inappropriately constructed and can include funds that don't use leverage or any derivative securities.

From

Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014), V. Results, 2. Shortcomings and SEC Guidance, p. 27
https://ssrn.com/abstract=2447306 · source PDF

Cite as

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

Holds when

responses to follow-up survey Question 6b(ii)

Classification

failuresupport: evidencedfailure: overbroad-leverage-definitionfamily: definitional-ambiguityprivate-fundsempirical-evidencesecurities-law

Verify

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Attestation record: colloquium/attestations/876a345f71a51f0e...json
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