# Raum

`kaal:entity:raum`

**Status.** derived

This node is assembled mechanically from the 8 claims that carry the concept tag `raum`. 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

8 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

**2014**

- [2447306-025](https://wulfkaal.github.io/claims/2447306-025) [empirical/evidenced] *(failure mode)* -- Regulatory assets under management is an unstable reporting concept: commenters split evenly on whether Form PF's RAUM questions required them to interpret the term in order to answer.
  > Commenters were equally split on whether Form PF questions pertaining to calculating RAUM required filers to interpret RAUM for purposes of completing Form PF.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2470008-030](https://wulfkaal.github.io/claims/2470008-030) [failure/evidenced] *(failure mode)* -- The Form PF definition of Regulatory Assets under Management is the leading example of a definition that forced filers to interpret what they were required to report.
  > Especially the definition of Regulatory Assets under Management (RAUM), as required by Form PF, required filers to interpret what they were required to report.
  Wulf A. Kaal, The Systemic Risk of Private Funds after the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2470008
- [2470008-032](https://wulfkaal.github.io/claims/2470008-032) [design/argued] -- Form PF instructions need clarification and its definitions, including those for RAUM and AUM, need improvement, since there is evidence that questions and definitions had to be optimized.
  > There is also evidence that Form PF questions and definitions had to be optimized, including performance information required by Form PF.177 Form PF instructions generally needs clarification and the definitions for RAUM/AUM in Form PF, among others, have to be improved.
  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

**2016**

- [2732915-013](https://wulfkaal.github.io/claims/2732915-013) [empirical/evidenced] -- The SEC estimates that 230 U.S. hedge fund advisers with at least $1.5 billion in RAUM attributable to hedge funds at the end of any month in the prior fiscal quarter will file Form PF.
  > The SEC estimates that 230 U.S. hedge fund advisers with at least $1.5 billion in RAUM attributable to hedge funds at the end of any month in the prior fiscal quarter will file Form PF.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2816408-027](https://wulfkaal.github.io/claims/2816408-027) [failure/argued] *(failure mode)* -- A single point in time RD design anchored to March 30, 2012 is inadequate on its own because advisers could and did register before the deadline, funds near the $150 million threshold could choose between registered adviser and exempt reporting adviser status, and self-reported Morningstar AUM is not calculated the same way as the SEC's RAUM.
  > Fourth, the self-reported assets under management numbers in Morningstar are not calculated the same way as the RAUM calculation required by the SEC.
  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**

- [2998097-024](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

## 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/raum.md | sha256sum

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