kaal:claim:2447306-037

Form PF fund performance metrics are not accurate or comparable across filers, because reporting entities employ different calculation methodologies to produce them.

Several respondents mentioned Form PF Item C., Question 17 (Reporting Fund Performance), suggesting that existing Form PF fund performance metrics are not accurate because the reporting entities employ different calculation methodologies.

Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014), V. Results, 2. Shortcomings and SEC Guidance, p. 31
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

• Form PF Item C, Question 17 on reporting fund performance

failuresupport: evidencedfailure: incomparable-performance-metricsfamily: data-quality-and-comparabilitydisclosureprivate-fundsempirical-evidence

• specializes kaal:claim:2348463-007 The SEC has not standardized the disclosures required in Form PF, and there is evidence that Form PF requireme...
• restated_by kaal:claim:2470008-023 Advisers take different approaches and make different assumptions when completing Form PF, which the SEC ident...

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