kaal:claim:2998097-014

Because advisers and third party service providers can flatten out and sanitize the information disclosed in Forms ADV and PF, the resulting disclosures may be less useful to the FSOC and the SEC in determining the systemic risk posed by private funds.

Although the level of sanitizing of disclosures could not be verified, sanitized disclosures could be less useful for Financial Stability Oversight Council (FSOC) and SEC evaluation and their determination of the systemic risk posed by private funds.84

Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017), IV.1.a Hedge Fund Manager Registration Under the Dodd-Frank Act, p. 20
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

• Forms ADV and PF disclosures
• level of sanitizing could not be verified in the study

failuresupport: arguedfailure: Sanitized disclosure degrades systemic risk datafamily: disclosure-ineffectivenessdisclosureprivate-fundssystemic-riskresearch-methodsrisk-and-incentives

• extends kaal:claim:2348463-022 Form PF disclosures have not been standardized, and anecdotal evidence indicates that the SEC and the FSOC may...
• restates kaal:claim:2150377-040 If advisers sanitize their Form ADV and Form PF filings, the disclosures become less useful for FSOC and SEC e...
• supports kaal:claim:2470008-039 Matching the identified Form PF defects against the FSOC's specific uses of that data suggests possible inaccu...
• extends kaal:claim:2150377-039 Mandatory reporting does not guarantee informative reporting: anecdotal evidence indicates that advisers can p...
• extends kaal:claim:2470008-038 Private fund advisers reporting under Form PF encountered issues that could affect the FSOC's systemic risk as...
• extends kaal:claim:2470008-001 The SEC data collected from private fund advisers feeds every stage of the FSOC's systemic risk assessment, an...

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