kaal:claim:2470008-004

Even though the private fund industry broadly accepted Form PF, the form's core problems for the SEC are the ambiguity of several questions, advisers' disagreement with the definition of funds, and correspondingly insufficient SEC guidance.

the core challenges for the SEC in Form PF include: the ambiguity of several questions on Form PF, private fund advisers' disagreement with the definition of funds in Form PF and corresponding insufficiency of SEC guidance

Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014), I. Introduction
https://ssrn.com/abstract=2470008 · source PDF

Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008

• Form PF as implemented by the SEC
• registered private fund advisers

failuresupport: evidencedfailure: Ambiguous questions and definitionsfamily: definitional-ambiguityprivate-fundssecurities-lawdisclosurecompliance

• extended_by kaal:claim:2998097-023 Form PF data suffer from core shortcomings: ambiguity in several key questions, inaccurate definitions with co...
• extends kaal:claim:2447306-027 Where SEC guidance failed, the failure was localized: respondents who found guidance inadequate pointed predom...
• restates kaal:claim:2447306-022 Asked what the SEC should fix first, respondents named the burdensome nature and the ambiguity of Form PF as t...
• extends kaal:claim:2447306-030 Regulatory flexibility can backfire: a category of respondents reported that the flexibility the SEC provides ...

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