kaal:claim:2470008-036

Widespread filer disagreement with Form PF definitions implies that a large share of filers are uncertain how to answer, which raises the possibility that they complete the form with estimates and varied assumptions.

This suggests that a large proportion of filers are uncertain as to how Form PF questions are to be answered. This uncertainty at least raises the possibility that the filers are using estimates and a variety of assumptions to complete Form PF.

Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014), 2. Impact on Systemic Risk Assessment
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

• filers who disagreed with Form PF definitions or instructions

mechanismsupport: arguedfailure: Estimates and assumptions substitute for measurementfamily: data-quality-and-comparabilityprivate-fundsdisclosure

• extended_by kaal:claim:2998097-025 If the FSOC relies on Form PF data that is subject to inaccuracies, because uncertain filers complete the form...

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