kaal:claim:2998097-024

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.

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.

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

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

• FSOC stage one threshold assessment
• Form PF valuation questions tied to RAUM

failuresupport: arguedfailure: Interpretive slack in RAUM propagates into designation thresholdsfamily: definitional-ambiguityprivate-fundssystemic-riskrisk-and-incentives

• extends kaal:claim:2470008-033 Because several core Form PF questions feeding the FSOC's stage one threshold screen are themselves defective,...
• extends kaal:claim:2470008-035 The Form PF counterparty questions most affected by filer interpretation, Questions 22 and 23, are the very on...
• supersedes kaal:claim:2470008-034 Because the FSOC uses RAUM related valuations directly and indirectly to set stage one thresholds, and because...
• supports kaal:claim:2470008-040 Fixing the identified problems with Form PF data would help optimize the FSOC's systemic risk assessment of pr...
• 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:2470008-031 The interpretation Form PF demands generated particular concern among filers about the definition of counterpa...
• extends kaal: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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