kaal:claim:2998097-012

The private fund industry's central fear about Form PF was not the filing itself but eventual publicity: if the disclosures ever became public, competitors could reverse engineer fund strategies and largely eliminate managers' ability to generate absolute returns.

the industry feared that such information could at some point in the future be made public which would largely eliminate private investment fund managers' ability to make absolute returns for their clients as competitors would be able to reverse engineer their strategies. Apart

Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017), IV. Dodd-Frank-Act, p. 17
https://ssrn.com/abstract=2998097 · source PDF

Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017). SSRN: https://ssrn.com/abstract=2998097

• Form PF disclosures held confidentially by the SEC

mechanismsupport: arguedfailure: Public disclosure would erode strategy valuefamily: disclosure-cost-and-burdenprivate-fundsdisclosure

• supports kaal:claim:2348463-031 Disclosing otherwise private and proprietary Form PF systemic risk data exclusively to bankruptcy judges could...

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