Several core Form PF questions that feed the FSOC's stage one threshold assessment are defective, most importantly because the definition of RAUM required substantive interpretation by the filers themselves.
Source quote, verbatim
Several core Form PF questions that provide specific information for FSOC's stage one threshold assessment encounter problems. More specifically, the definition of RAUM required substantive interpretation by filers.
From
Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017), IV.2 Systemic Risk, p. 35 https://ssrn.com/abstract=2998097 · source PDF
Cite as
Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017). SSRN: https://ssrn.com/abstract=2998097
Holds when
FSOC stage one threshold assessment
Form PF valuation questions tied to RAUM
Classification
failuresupport: arguedfailure: Interpretive slack in RAUM propagates into designation thresholdsfamily: definitional-ambiguityprivate-fundssystemic-riskrisk-and-incentives
Related claims
extendskaal:claim:2470008-033 Because several core Form PF questions feeding the FSOC's stage one threshold screen are themselves defective,...
extendskaal:claim:2470008-035 The Form PF counterparty questions most affected by filer interpretation, Questions 22 and 23, are the very on...
supersedeskaal:claim:2470008-034 Because the FSOC uses RAUM related valuations directly and indirectly to set stage one thresholds, and because...
supportskaal:claim:2470008-040 Fixing the identified problems with Form PF data would help optimize the FSOC's systemic risk assessment of pr...
extendskaal:claim:2470008-038 Private fund advisers reporting under Form PF encountered issues that could affect the FSOC's systemic risk as...
extendskaal:claim:2470008-031 The interpretation Form PF demands generated particular concern among filers about the definition of counterpa...
extendskaal:claim:2470008-039 Matching the identified Form PF defects against the FSOC's specific uses of that data suggests possible inaccu...
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