# No action letters

`kaal:entity:no-action-letters`

**Status.** derived

This node is assembled mechanically from the 2 claims that carry the concept tag `no-action-letters`. 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

2 claims across 2 works, 2011 to 2012.

**2011**

- [1806252-018](https://wulfkaal.github.io/claims/1806252-018) [mechanism/argued] -- A lack of regulatory guidance creates legal uncertainty, and legal uncertainty in turn generates transaction costs.
  > A lack of guidance may create legal uncertainty,!4° and legal uncertainty generates transaction costs.
  Kaal, Hedge Fund Regulation Via Basel III (2011). SSRN: https://papers.ssrn.com/sol3/papers.cfm?abstract_id=1806252

**2012**

- [2150377-004](https://wulfkaal.github.io/claims/2150377-004) [failure/argued] *(failure mode)* -- Before Dodd-Frank the perimeter of hedge fund regulation was set by SEC no-action letters on client counting and by courts that gave very limited and sometimes contradictory guidance, so compliance rested on an unstable and uncertain base rather than on rules.
  > However, the SEC continued to provide guidance mostly in the form of no-action letters to help investment advisers determine the counting of clients to stay exempt from securities regulation.44 Courts also provided very limited and sometimes contradictory guidance.45
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377

## 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/no-action-letters.md | sha256sum

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