kaal:claim:2470008-022

The SEC itself reports that the consistency of investment advisers' responses on Form PF is not ensured and may be questionable.

The analysis of the data collected in Form PF presents several key challenges. The SEC suggests that the consistency of investment adviser's responses on Form PF is not ensured and could be questionable.

Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014), 1. Sub-optimality of Systemic Risk Data
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 filings as analyzed by SEC staff

failuresupport: evidencedfailure: Inconsistent adviser responsesfamily: data-quality-and-comparabilityprivate-fundssecurities-lawdisclosure

• supports kaal:claim:2447306-004 If advisers' allegations that Form PF disclosures cannot be answered other than by guessing are correct, then ...
• supports kaal:claim:2348463-007 The SEC has not standardized the disclosures required in Form PF, and there is evidence that Form PF requireme...

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