# Fsoc

`kaal:entity:fsoc`

**Status.** derived

This node is assembled mechanically from the 36 claims that carry the concept tag `fsoc`. 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

36 claims across 9 works, 2012 to 2017.

**2012**

- [2150377-010](https://wulfkaal.github.io/claims/2150377-010) [empirical/evidenced] -- Form PF reporting achieves broad coverage of systemic exposure with narrow coverage of firms: the SEC expects the small set of large filers to account for eighty percent of total hedge fund assets under management in the United States.
  > The SEC expects this relatively small number of advisers to account for 80% of total hedge fund assets under management in the United States.145
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-011](https://wulfkaal.github.io/claims/2150377-011) [design/evidenced] -- Quarterly rather than annual Form PF updating for large hedge fund advisers is designed for timeliness: its purpose is to give the Financial Stability Oversight Council data current enough to identify emerging trends in systemic risk.
  > Mandatory quarterly reporting for large hedge fund advisers in the United States aligns with international trends and is intended "to provide the FSOC with timely data to identify emerging trends in systemic risk."151
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-040](https://wulfkaal.github.io/claims/2150377-040) [failure/speculative] *(failure mode)* -- If advisers sanitize their Form ADV and Form PF filings, the disclosures become less useful for FSOC and SEC evaluation and undermine the very determination of systemic risk posed by private funds that the reporting regime was built to enable.
  > Although the level of sanitizing of disclosures cannot be verified, sanitized disclosures could be less useful for FSCO and SEC evaluation and their determination of the systemic risk posed by private funds.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377

**2013**

- [2337268-021](https://wulfkaal.github.io/claims/2337268-021) [design/asserted] -- Form PF was created to improve SEC and CFTC investigations and examinations and to enable the Financial Stability Oversight Council to monitor systemic risk in U.S. financial markets.
  > Form PF was enacted in October 201164 to improve investigations and examinations by the SEC and the Commodity Futures Trading Commission (CFTC) and to facilitate the FSOC's65 monitoring of systemic risk in U.S. financial markets.66
  Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268
- [2337268-024](https://wulfkaal.github.io/claims/2337268-024) [design/argued] -- Quarterly rather than annual reporting by large private fund advisers is intended to give the FSOC data timely enough to identify emerging systemic risk trends.
  > The quarterly reporting for large private fund advisers is intended to provide the FSOC with timely data to identify emerging trends in systemic risk.
  Wulf A. Kaal, Investment Adviser Regulation (2013). SSRN: https://ssrn.com/abstract=2337268
- [2348463-017](https://wulfkaal.github.io/claims/2348463-017) [design/evidenced] -- Mandatory quarterly Form PF reporting for large hedge fund advisers is designed to give the Financial Stability Oversight Council timely data for identifying emerging systemic risk trends and to align United States practice with international trends.
  > Mandatory quarterly reporting for large hedge fund advisers in the United States is intended to provide the FSOC with timely data to identify emerging trends in systemic risk and align with international trends.
  Wulf A. Kaal, Hedge Funds’ Systemic Risk Disclosures in Bankruptcy (2013). SSRN: https://ssrn.com/abstract=2348463
- [2348463-022](https://wulfkaal.github.io/claims/2348463-022) [failure/evidenced] *(failure mode)* -- Form PF disclosures have not been standardized, and anecdotal evidence indicates that the SEC and the FSOC may be working with contradictory, misleading, inaccurate, and incomplete systemic risk data.
  > Form PF disclosures have not yet been standardized, and anecdotal evidence suggests that the SEC and the FSOC could be working with contradictory, misleading, inaccurate, and incomplete systemic risk data in Form PF.
  Wulf A. Kaal, Hedge Funds’ Systemic Risk Disclosures in Bankruptcy (2013). SSRN: https://ssrn.com/abstract=2348463

**2014**

- [2389416-011](https://wulfkaal.github.io/claims/2389416-011) [design/asserted] -- The quarterly Form PF reporting obligation imposed on hedge fund advisers with more than $1.5 billion in regulatory assets under management is designed to give the FSOC timely data for identifying systemic risk trends.
  > The quarterly reporting requirement for large hedge fund advisers is intended to provide timely data that enables the FSOC to identify trends in systemic risk (IA Release 3308).
  Wulf A. Kaal, Barbara Luppi, Sandra Paterlini, Did the Dodd-Frank Act Impact Hedge Fund Performance (2014). SSRN: https://ssrn.com/abstract=2389416
- [2470008-001](https://wulfkaal.github.io/claims/2470008-001) [failure/argued] *(failure mode)* -- The SEC data collected from private fund advisers feeds every stage of the FSOC's systemic risk assessment, and the FSOC leans most heavily on precisely those disclosure items that are the most problematic.
  > The author shows that while the SEC's data plays a crucial role in all stages of FSOC's systemic risk assessment of private fund advisers, the FSOC relies most heavily on some of the most problematic disclosure items collected by the SEC.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-002](https://wulfkaal.github.io/claims/2470008-002) [failure/argued] *(failure mode)* -- Accuracy and consistency problems in the SEC's private fund data collection can impair the FSOC's ability to evaluate the systemic risk posed by private fund advisers.
  > Evidence that the SEC's data collection encounters accuracy and consistency problems might hamper the FSOC's ability to evaluate the systemic risk of private fund advisers.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-003](https://wulfkaal.github.io/claims/2470008-003) [empirical/evidenced] *(failure mode)* -- Prior studies and anecdotal evidence indicate that the data collection mandated by Form PF could itself create problems for the FSOC when it evaluates hedge fund systemic risk.
  > Several observations from previous studies and anecdotal evidence suggest that the mandated data collection in Form PF could create issues for FSOC in evaluating the systemic risk of hedge funds.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-014](https://wulfkaal.github.io/claims/2470008-014) [design/argued] -- Form PF data was tailored primarily for the FSOC rather than for the SEC's own purposes, a design choice that shaped the level of reporting required.
  > The data collected via Form PF has been tailored primarily for the use of the FSOC.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-015](https://wulfkaal.github.io/claims/2470008-015) [empirical/argued] -- The FSOC's powers over nonbank financial institutions are broad and without precedent in United States financial regulation.
  > The FSOC's powers over nonbank financial institutions are broad and unprecedented in U.S. financial regulation.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-016](https://wulfkaal.github.io/claims/2470008-016) [mechanism/argued] -- The quantitative measures used in systemic risk assessment are not codified in statute, so the FSOC can alter its thresholds and its analysis through rulemaking.
  > the quantitative systemic risk assessment measures are not specifically codified and the FSOC can change thresholds and analysis via the rule making process
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-017](https://wulfkaal.github.io/claims/2470008-017) [condition/asserted] -- Commonly managed investment funds holding $50 billion or more in aggregate total consolidated assets can be designated systemically important, and following a similar investment strategy across those funds makes designation more likely.
  > Commonly managed investment funds that manage $50 billion or more in the aggregate of total consolidated assets could be designated a SIFI, particularly if such funds all follow a similar investment strategy.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-018](https://wulfkaal.github.io/claims/2470008-018) [mechanism/asserted] -- Stage one of the FSOC's designation process is a mechanical screen: six quantitative thresholds filter out nonbank financial institutions unlikely to pose significant systemic risk before any institution specific or qualitative analysis begins.
  > In stage one, applying six quantitative thresholds, FSOC uses a mechanical screening process to eliminate those nonbank financial institutions from review that are unlikely to pose significant systemic risk and may not merit SIFI designation.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-020](https://wulfkaal.github.io/claims/2470008-020) [mechanism/argued] -- The FSOC's three stage SIFI review process depends heavily on information that private fund investment advisers supply through Form PF.
  > FSOC's three-stage review process for SIFI designation153 depends heavily on the information provided by private fund investment advisers in Form PF.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-021](https://wulfkaal.github.io/claims/2470008-021) [mechanism/argued] -- Form PF information addresses most of the FSOC's stage one thresholds either directly or indirectly, so the mechanical screen runs largely on adviser reported data.
  > The information in Form PF either directly or indirectly addresses most of FSOC's stage one thresholds.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-027](https://wulfkaal.github.io/claims/2470008-027) [empirical/evidenced] *(failure mode)* -- The FSOC itself conceded that available data was insufficient when it tried to identify the activities of the twenty largest United States fund managers as possible sources of systemic risk.
  > Similarly, in its attempt to identify activities of twenty of the largest U.S. fund managers as possible sources of systemic risk,171 the FSOC acknowledged that the available data was insufficient
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-033](https://wulfkaal.github.io/claims/2470008-033) [failure/argued] *(failure mode)* -- Because several core Form PF questions feeding the FSOC's stage one threshold screen are themselves defective, the FSOC's systemic risk assessment process could be compromised.
  > Given the identified shortcomings of Form PF data, the systemic risk assessment process employed by the FSOC could be compromised. Several core Form PF questions that provide specific information for FSOC's stage one threshold assessment encounter problems.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-034](https://wulfkaal.github.io/claims/2470008-034) [failure/argued] *(failure mode)* -- Because the FSOC uses RAUM related valuations directly and indirectly to set stage one thresholds, and because RAUM requires substantial filer interpretation, it is questionable whether the FSOC can use that Form PF data effectively and sustainably for systemic risk evaluations and SIFI designations.
  > it seems at least questionable if FSOC will be able to use the related Form PF data effectively and sustainably for its systemic risk evaluations and the designation of non-bank financial companies as systemically risky
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-035](https://wulfkaal.github.io/claims/2470008-035) [failure/argued] *(failure mode)* -- The Form PF counterparty questions most affected by filer interpretation, Questions 22 and 23, are the very ones the FSOC uses in stage two to determine the interconnectedness of private funds.
  > Form PF questions 22 and 23 are directly used in FSOC's stage two analysis to determine the interconnectedness of private funds.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-037](https://wulfkaal.github.io/claims/2470008-037) [condition/argued] *(failure mode)* -- If the FSOC relies on inaccurate Form PF data in its systemic risk assessment, its work on private funds may itself be erroneous.
  > If FSOC relies on Form PF data in its systemic risk assessment that is subject to inaccuracies, it appears possible that FSOC's work pertaining to private funds could in turn be subject to errors.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-038](https://wulfkaal.github.io/claims/2470008-038) [failure/argued] *(failure mode)* -- Private fund advisers reporting under Form PF encountered issues that could affect the FSOC's systemic risk assessment, but the author does not claim that the FSOC is unable to fulfill its congressional mandate.
  > The article suggests that private fund advisers who reported data as required by SEC Form PF encountered issues that could affect FSOC's systemic risk assessment of private funds. The author does not suggest that the FSOC is unable to fulfill Congress's mandate.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-039](https://wulfkaal.github.io/claims/2470008-039) [failure/argued] *(failure mode)* -- Matching the identified Form PF defects against the FSOC's specific uses of that data suggests possible inaccuracies in the FSOC's systemic risk assessment process, although the author disclaims scientific or empirical precision for the analysis.
  > The matching of identified Form PF issues with FSOC's respective use of such suboptimal Form PF data suggests that possible inaccuracies may exist in FSOC's systemic risk assessment process. The author does not claim scientific and/or empirical precision in the analysis.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-040](https://wulfkaal.github.io/claims/2470008-040) [normative/argued] -- Fixing the identified problems with Form PF data would help optimize the FSOC's systemic risk assessment of private funds.
  > Addressing the identified problems with Form PF data could help optimize FSOC's systemic risk assessment of private funds.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008

**2016**

- [2715083-004](https://wulfkaal.github.io/claims/2715083-004) [mechanism/argued] -- Lifting the advertising ban for hedge fund advisers under the JOBS Act, combined with FSOC treating mutual and hedge funds alike for SIFI designation, effectively assimilated the advertising requirements applicable to the two asset classes.
  > Similarly, the removal of advertising restrictions for hedge fund advisers under the JOBS Act and the equal treatment of mutual and hedge funds for FSOC's SIFI designation in effect assimilated the advertising requirements of mutual and hedge funds.
  Kaal, Confluence of Mutual and Private Funds (2016). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2715083
- [2715083-026](https://wulfkaal.github.io/claims/2715083-026) [failure/argued] *(failure mode)* -- FSOC's SIFI designation framework does not distinguish between mutual and hedge funds, even though evidence indicates designation would have disparate effects on the two asset classes.
  > While evidence exists that SIFI designation could have disparate affects on mutual and hedge funds (Stevens Letter (2015), the applicable regulatory framework does not distinguish between the two asset classes.44
  Kaal, Confluence of Mutual and Private Funds (2016). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2715083
- [2748096-027](https://wulfkaal.github.io/claims/2748096-027) [empirical/asserted] -- The FSOC's powers over hedge funds and other nonbank financial institutions are broad and unprecedented in U.S. financial regulation, including the power to subject hedge funds to extensive Federal Reserve supervision and to designate a fund systemically important on its own initiative by a two-thirds vote.
  > The FSOC's powers over hedge funds and other nonbank financial institutions are broad and unprecedented in U.S. financial regulation. The FSOC has the power to subject hedge funds to extensive supervision by the Federal Reserve.
  Wulf A. Kaal, Timothy A. Krause, Hedge Funds and Systemic Risk (2016). SSRN: https://ssrn.com/abstract=2748096
- [2748096-028](https://wulfkaal.github.io/claims/2748096-028) [failure/argued] *(failure mode)* -- The SIFI designation regime does not reach hedge funds in practice: because the asset threshold is set high, at $50 billion or more in aggregate total consolidated assets, hedge funds are unlikely to be designated as systemically important financial institutions.
  > However, hedge funds are unlikely to be designated as SIFIs because of the high threshold on AUM.
  Wulf A. Kaal, Timothy A. Krause, Hedge Funds and Systemic Risk (2016). SSRN: https://ssrn.com/abstract=2748096
- [2816408-013](https://wulfkaal.github.io/claims/2816408-013) [design/asserted] -- The quarterly Form PF reporting obligation imposed on advisers with more than $1.5 billion in regulatory assets under management attributable to private funds exists to give the FSOC timely data for identifying trends in systemic risk.
  > The quarterly reporting requirement for large private fund advisers is intended to provide timely data that enables the FSOC to identify trends in systemic risk (IA Release 3308).
  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**

- [2998097-014](https://wulfkaal.github.io/claims/2998097-014) [failure/argued] *(failure mode)* -- 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). SSRN: https://ssrn.com/abstract=2998097
- [2998097-021](https://wulfkaal.github.io/claims/2998097-021) [failure/evidenced] *(failure mode)* -- The SEC's private fund data collection encountered accuracy and consistency problems that hampered the FSOC's ability to evaluate the systemic risk of private funds.
  > The paper created and evaluated data evidence that demonstrated that the SEC's data collection encountered accuracy and consistency problems that hampered the FSOC's ability to evaluate the systemic risk of private funds.141 The author
  Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017). SSRN: https://ssrn.com/abstract=2998097
- [2998097-022](https://wulfkaal.github.io/claims/2998097-022) [failure/evidenced] *(failure mode)* -- The FSOC relied most heavily on some of the most problematic disclosure items the SEC collects, even though SEC data played a crucial role at every stage of its systemic risk assessment of private funds.
  > The author showed that while the SEC's data played a crucial role in all stages of FSOC's systemic risk assessment of private funds, the FSOC relied most heavily on some of the most problematic disclosure items collected by the SEC.
  Wulf A. Kaal, Private Investment Fund Regulation - Theory and Empirical Evidence from 1998 to 2016 (2017). SSRN: https://ssrn.com/abstract=2998097
- [2998097-024](https://wulfkaal.github.io/claims/2998097-024) [failure/argued] *(failure mode)* -- 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). SSRN: https://ssrn.com/abstract=2998097
- [2998097-025](https://wulfkaal.github.io/claims/2998097-025) [failure/argued] *(failure mode)* -- If the FSOC relies on Form PF data that is subject to inaccuracies, because uncertain filers complete the form using estimates and assumptions, then the FSOC's own work on private funds may in turn be subject to errors.
  > If FSOC relied on Form PF data in its systemic risk assessment that is subject to inaccuracies, the paper suggested that it appeared possible that FSOC's work pertaining to private funds could in turn be subject to errors.149
  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. Nothing here asks to be taken on trust.

    curl -s https://wulfkaal.github.io/entities/fsoc.md | sha256sum

**Canonical form.** This markdown file is the canonical hashed representation of this entity node. Its sha256 is the content hash.