kaal:claim:2470008-023

Advisers take different approaches and make different assumptions when completing Form PF, which the SEC identifies as a further challenge to the usability of the data.

Other challenges with Form PF identified by the SEC include the differences in approaches taken by investment advisers in completing Form PF and differences in assumptions made by investment advisers in completing Form PF.

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 by registered private fund advisers

failuresupport: evidencedfailure: Non comparable filing methodologiesfamily: data-quality-and-comparabilityprivate-fundssecurities-law

• supports kaal:claim:2447306-004 If advisers' allegations that Form PF disclosures cannot be answered other than by guessing are correct, then ...
• extends kaal:claim:2447306-029 SEC flexibility helps filers through a specific mechanism: it authorizes advisers to apply their own internal ...
• restates kaal:claim:2447306-037 Form PF fund performance metrics are not accurate or comparable across filers, because reporting entities empl...

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