# Form adv `kaal:entity:form-adv` **Status.** derived This node is assembled mechanically from the 19 claims that carry the concept tag `form-adv`. It is a roster of what the corpus says under this term. It is **not** an adjudicated definition: no single statement here has been ruled canonical, and no first-appearance call has been made. Read the claims and judge for yourself. ## Every claim under this term 19 claims across 6 works, 2012 to 2017. **2012** - [2150377-009](https://wulfkaal.github.io/claims/2150377-009) [design/evidenced] -- Revised Form ADV requires advisers to report gross rather than net regulatory assets under management and narrows their discretion to include or exclude assets, so the registration threshold becomes harder to manage down through reporting choices. > To increase consistency, revised Form ADV also gives investment advisers less room to exercise discretion in counting or excluding assets from RAUM.115 Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377 - [2150377-015](https://wulfkaal.github.io/claims/2150377-015) [failure/evidenced] *(failure mode)* -- Mandated disclosure does not automatically produce usable public data: although Form ADV requires advisers to disclose chief compliance officer contact information, the SEC dataset omitted it and contained no e-mail addresses, so researchers could not reach the officers responsible for compliance. > Although Form ADV requires advisers to disclose the contact information for their chief compliance officer, the dataset provided by the SEC did not list this information and did not include e-mail addresses. Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377 - [2150377-019](https://wulfkaal.github.io/claims/2150377-019) [empirical/evidenced] -- Comparison of the responding sample against the full registered population on Form ADV parameters shows the sample is not biased toward any particular subgroup of hedge fund advisers, and gives no indication that respondents differ from nonrespondents. > The descriptive statistics demonstrate that the sample is not biased and does not favor a particular subgroup of hedge fund advisers.189 There is no indication that respondents who did respond to the survey were different from individuals who did not respond. Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377 - [2150377-039](https://wulfkaal.github.io/claims/2150377-039) [mechanism/speculative] *(failure mode)* -- Mandatory reporting does not guarantee informative reporting: anecdotal evidence indicates that advisers can present the information required in Forms ADV and PF in ways that in effect flatten out and sanitize the disclosures. > Anecdotal evidence suggests that the information disclosed by hedge fund advisers in the required Forms ADV and PF can be presented in ways that in effect "flatten out" and "sanitize" the disclosures. Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377 **2013** - [2337268-019](https://wulfkaal.github.io/claims/2337268-019) [design/asserted] -- Part 2 of Form ADV requires a plain English narrative brochure for prospective advisory customers, making the brochure the primary disclosure document delivered to an adviser's clients. > Part 2 of Form ADV requires investment advisers to provide a narrative brochure in plain English to prospective advisory customers. The brochure should contain the information set forth in Form ADV Part 2.44 Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268 - [2337268-020](https://wulfkaal.github.io/claims/2337268-020) [design/argued] -- Mandatory disclosure of referral compensation, related person status of brokers and dealers, and soft dollar benefits is designed to defuse conflicts of interest arising when an adviser runs several types of business and services. > investment advisers must disclose compensation given or received for client referrals,55 related persons status of brokers and dealers,56 and soft dollar benefits, i.e., research or other products and services received in connection with client transactions.57 Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268 - [2337268-022](https://wulfkaal.github.io/claims/2337268-022) [design/asserted] -- Form PF filings, unlike Form ADV filings, are confidential and not publicly available, so the systemic risk disclosure regime is built for regulators rather than for market or investor scrutiny. > Unlike Form ADV, Form PF filings are confidential and not publicly available. Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268 **2014** - [2389416-040](https://wulfkaal.github.io/claims/2389416-040) [empirical/evidenced] -- The SEC's collection of proprietary hedge fund data through Forms ADV and PF does not negatively affect the performance of the hedge fund industry as a whole, and appears to affect only a subset of the industry. > The preliminary results in this study suggest that the SEC's collection of proprietary hedge fund data via Forms ADV and PF does not negatively impact the hedge fund industry's performance as a whole. It seems to affect merely a subset of the hedge fund industry. Wulf A. Kaal, Barbara Luppi, Sandra Paterlini, Did the Dodd-Frank Act Impact Hedge Fund Performance (2014). SSRN: https://ssrn.com/abstract=2389416 **2016** - [2811718-001](https://wulfkaal.github.io/claims/2811718-001) [empirical/evidenced] -- The study rests on two datasets: SEC Form ADV Part II filings by private investment fund advisers from 2007 to 2014 (N=100392) and the publicly available litigation record on private fund investor due diligence from 1995 to 2015 (N=572). > the author examines two datasets: (1) private investment fund advisers' SEC Form ADV II filings from 2007 to 2014 (N=100392), and (2) the publicly available litigation record pertaining to private fund investor due diligence from 1995 to 2015 (N=572). Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2811718-007](https://wulfkaal.github.io/claims/2811718-007) [mechanism/argued] -- Because a material omission or misstatement in Form ADV Part 2A can support a serious securities law charge, private fund managers have an incentive to keep the narrative language of that required disclosure as high level, summary, and non committal as possible. > the imperative for a private fund manager is to keep the narrative language as high-level, summary, and as non-committal as possible, because a material omission and/or misstatement in that section could lead to a serious charge of violating the securities laws. Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2811718-008](https://wulfkaal.github.io/claims/2811718-008) [empirical/evidenced] -- From 2007 to 2014 an increasing number of Form ADV Part II filers deemed investor due diligence worth mentioning, and an increasing number of filers qualitatively increased their due diligence disclosures in the brochure filings. > In sum, Figure 2 demonstrates that from 2007 to 2014 an increasing number of ADV II filers deem IDD worth mentioning, and an increasing number of ADV II filers qualitatively increased their due diligence disclosures in Form ADV II brochure filings. Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2811718-009](https://wulfkaal.github.io/claims/2811718-009) [empirical/evidenced] -- Since 2010 an increasing number of SEC Form ADV Part II brochure filers included investor due diligence disclosures, but the number of filers including such disclosures remained relatively even between 2012 and 2014. > an increasing number of SEC Form ADV II brochure filers included IDD disclosures and the number of filers who include those disclosures has remained relatively even between 2012 and 2014. Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2811718-010](https://wulfkaal.github.io/claims/2811718-010) [empirical/evidenced] -- The intensity of due diligence mentioning relative to total Form ADV Part II brochure filings increased substantially, and the due diligence count exceeded the total number of ADV II filings for the first time in 2014. > The intensity of IDD mentioning relative to total SEC Form ADV II brochure filings has increased substantially; the due diligence count exceeded the total ADV II filings for the first time in 2014. Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2811718-011](https://wulfkaal.github.io/claims/2811718-011) [empirical/evidenced] -- Form ADV Part II filings jumped from 3,024 in 2010 to 21,685 in 2011, and that jump was accompanied by a corresponding increase both in the number of filings mentioning investor due diligence and in the due diligence counts within those filings. > After 2010, a noticeable increase in filings—from 3,024 filings in 2010 to 21,685 filings in 2011—is accompanied by a corresponding increase in filings mentioning IDD and an increase in the due diligence counts in such filings. Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2811718-012](https://wulfkaal.github.io/claims/2811718-012) [empirical/evidenced] -- Although overall Form ADV Part II filings fell between 2012 and 2013, due diligence counts fell only marginally, from 20,828 to 20,031, and filings mentioning due diligence fell from 7,862 to 7,198, less than proportionally to the drop in total filings. > While the overall filings between 2012 and 2013 depreciated, the ratio of due diligence counts is only marginally affected (depreciating from 20,828 to 20,031) and filings that mention due diligence decreased (depreciating from 7,862 to 7,198) in relation to the overall filing depreciation. Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2811718-013](https://wulfkaal.github.io/claims/2811718-013) [empirical/argued] *(failure mode)* -- The Form ADV analysis is limited because the term due diligence carries multiple possible meanings, so counts of the term cannot by themselves distinguish among those meanings. > The data analysis in Figures 1 and 2 is limited by multiple possible meanings of the term due diligence. Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2811718-035](https://wulfkaal.github.io/claims/2811718-035) [mechanism/evidenced] -- The data suggest that since 2010 private fund advisers increasingly engage in investor due diligence in order to protect themselves from investor criticism and lawsuits. > The data provided in this study seems to suggest that private fund advisers since 2010 increasingly engage in private fund IDD to protect themselves from investor criticism and lawsuits. Wulf A. Kaal, Private Fund Investor Due Diligence – Evidence from 1995 to 2015 (2016). SSRN: https://ssrn.com/abstract=2811718 - [2816408-028](https://wulfkaal.github.io/claims/2816408-028) [design/argued] -- To sharpen assignment to treatment and control, actual registration histories were pulled from the SEC's IAPD website and historical Form ADV data and combined with Morningstar variables to build two additional control groups: firms already registered with no status change, and foreign firms completely unaffected by the US legal regime. > create two additional control groups of exempt reporting advisers (ERAs): (1) only firms that were already registered and had no change in status, and (2) foreign firms that are completely unaffected by the US legal regime. Wulf A. Kaal, Barbara Luppi, Sandra Paterlini, Did the Dodd-Frank Act Impact Private Fund Performance – Evidence from 2010 – 2015 (2016). SSRN: https://ssrn.com/abstract=2816408 **2017** - [2998097-029](https://wulfkaal.github.io/claims/2998097-029) [empirical/evidenced] -- Since 2010 private fund advisers increasingly engaged in investor due diligence partly to protect themselves from investor criticism and lawsuits, rather than in response to regulatory mandate. > the data provided in the author's study suggested that since 2010 private fund advisers increasingly engaged in private fund investor due diligence, partially in an effort to protect themselves from investor criticism and lawsuits.163 Since Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017). SSRN: https://ssrn.com/abstract=2998097 ## Verify Every claim above resolves to a record carrying a verbatim source quote, the sha256 of the source PDF, and a preformatted citation. 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