entity · derived
Survey results
Derived node: assembled mechanically from the claims carrying survey-results. A roster, not an adjudicated definition.
Every claim under this term
- 2150377-020 : Advisers responded to Dodd-Frank registration mainly through administrative and advisory adjustments: the most common actions were outsourcing compliance work, hiring additional counsel, instituting n
- 2150377-021 : Structural and portfolio level responses to registration were rare: only a minority of respondents severed an advising relationship, changed a fund's legal structure, liquidated positions, changed inv
- 2150377-022 : A majority of surveyed advisers, 72.09%, do not plan any strategic response to the Dodd-Frank Act registration and reporting requirements.
- 2150377-023 : Compliance with the registration and disclosure requirements cost a majority of surveyed advisers between $50,000 and $200,000, while a significant minority estimated total compliance cost from $200,0
- 2150377-024 : The time burden of complying with all federal rules applicable to hedge fund advisers has a median of 500 hours per year, with three quarters of respondents at 750 hours or less and a quarter above th
- 2150377-025 : The regulatory regime does not drive fund sizing for most advisers: 82.02% of respondents would not take the current regulatory regime into account in determining the assets under management size of t
- 2150377-026 : Among the minority of advisers who do factor regulation into fund sizing, the pressure runs in both directions: about 25% would go smaller to avoid regulatory hassle while about 50% would grow or need
- 2150377-027 : The Form PF quarterly reporting threshold of $1.5 billion in assets under management is not a binding sizing constraint for most advisers: 80.46% would not take it into account in determining fund siz
- 2150377-028 : Where the Form PF quarterly reporting threshold does influence behavior, it distorts fund size downward: a majority of the advisers who take the threshold into account plan to stay under $1.5 billion
- 2150377-029 : Registration and disclosure costs had not reached investors at the time of the survey: 76.09% of respondents reported that their investors' rate of return was not affected, while 23.91% believed inves
- 2150377-030 : The incidence of Dodd-Frank compliance cost falls on the management company rather than the fund: the responses indicate that the management company bears the brunt of registration and disclosure cost
- 2150377-031 : Of the respondents reporting an effect on management company profits, 87.50% attributed it specifically to increased costs and decreased profits caused by the registration and reporting requirements.
- 2150377-032 : Registration and disclosure did not push advisers to change what they invest in: only 2.44% of respondents said they would have to change strategy significantly over five years, while 4.88% expressly
- 2150377-033 : Respondents identified the creation of barriers to entry as an industry level effect of the registration and disclosure requirements, because the rules make the market environment for private funds le
- 2150377-034 : The compliance burden has raised the minimum viable scale for launching a hedge fund: an adviser reports that the capital needed to start a fund in New York rose from roughly $25 to $50 million to at
- 2150377-036 : Despite documented cost concerns, the hedge fund industry appears to be only modestly affected by the Dodd-Frank reporting and disclosure requirements and is adapting well to the new regulatory enviro
- 2150377-037 : Strategic adjustment to registration is a function of firm size: firms that planned a strategic response to Dodd-Frank were smaller than firms that did not.
- 2447306-011 : Advisers themselves understand Form PF's purpose the way the statute frames it: most respondents identified assessing systemic risk and closing the historical information gap about private funds as th
- 2447306-012 : Initial Form PF compliance was inexpensive for most filers: 59.18 percent of respondents put the total cost of completing Form PF for the first time under $10,000.
- 2447306-013 : Form PF compliance cost is sharply size dependent: quarterly filing large funds spent on average $155,286 on the initial filing, roughly sixteen times the $9,520 average reported by annually filing sm
- 2447306-014 : Measured against this study's survey data, the SEC marginally overestimated the cost of the initial Form PF filing for both annually filing smaller advisers and quarterly filing larger advisers.
- 2447306-015 : Recurring Form PF cost is also size dependent: quarterly filing large fund advisers pay on average $72,143 for subsequent filings while smaller advisers spend on average $5,262.
- 2447306-018 : The SEC's time burden estimates for Form PF are miscalibrated in the same direction as its cost estimates for large filers: the study's data suggest the agency overestimates the hours larger private f
- 2447306-019 : Form PF compliance is not staff intensive for most filers: 67.35 percent of respondents used only one to three individuals and 69.39 percent reported the work took staff less than 50 hours.
- 2447306-020 : The Form PF burden is concentrated in a few identifiable items: respondents ranked Question 16 on types of investors as the most time consuming, followed by Question 17 on performance and Question 7 o
- 2447306-021 : The dominant driver of Form PF time consumption is data gathering rather than form completion: 36 percent of respondents named data gathering as the task consuming most of their time, followed by delt
- 2447306-022 : Asked what the SEC should fix first, respondents named the burdensome nature and the ambiguity of Form PF as the most pressing issues, not the substance of what is disclosed.
- 2447306-023 : Complaints about Form PF's ambiguity coexist with acceptance of its substance: the same majority that flagged ambiguity as the most pressing issue also considered their existing reporting systems adeq
- 2447306-024 : Form PF's definition of leverage is overinclusive: respondents reported that it is inappropriately constructed and sweeps in funds that use neither leverage nor derivative securities.
- 2447306-025 : 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.
- 2447306-026 : Contrary to the industry's public complaints about SEC support, a majority of respondents rated the best level of SEC staff guidance available for completing Form PF as sufficient or good.
- 2447306-027 : Where SEC guidance failed, the failure was localized: respondents who found guidance inadequate pointed predominantly to Form PF Section 1c, Item B, which concerns information about the reporting fund
- 2447306-028 : SEC flexibility in answering Form PF questions is valued by filers: 72.92 percent of respondents said the flexibility the SEC provides is helpful.
- 2447306-031 : Most private fund advisers did not need new infrastructure to comply: 65.22 percent reported that their existing internal reporting systems adequately capture the information Form PF requires.
- 2447306-032 : For a substantial minority, existing systems fail Form PF for a specific reason: 34.78 percent of respondents said their internal reporting systems were insufficient because the required answers deman
- 2447306-033 : Form PF's counterparty disclosure proved far less burdensome in practice than anticipated: 93.75 percent of respondents encountered no difficulty identifying counterparties for the counterparty credit
- 2447306-034 : Because only 27.08 percent of respondents used a service provider to complete Form PF, the widespread concern that outside service providers would overinterpret required Form PF data on filers' behalf
- 2447306-035 : Working with a service provider imposes its own costs: filers reported that the arrangement requires investing time and money to develop interaction processes and bearing the burden of supplying the p
- 2447306-036 : Investor demand for Form PF filings is limited: 74.47 percent of respondents had never been asked by an investor for a copy of their Form PF filing.
- 2447306-037 : Form PF fund performance metrics are not accurate or comparable across filers, because reporting entities employ different calculation methodologies to produce them.
- 2447306-038 : Respondents argued that the SEC's systemic risk objective would have been advanced more directly by asking a smaller set of targeted questions, emphasizing open derivatives positions, the entity's tot
- 2732915-018 : A majority of private fund adviser respondents, 74.5 percent, do not plan any strategic response to Title IV of the Dodd-Frank Act.
- 2732915-019 : The most common adviser responses to Title IV are outsourcing compliance work, hiring additional counsel, instituting new record keeping policies, hiring additional staff, changing marketing materials
- 2732915-020 : Private fund advisers in the sample did not terminate existing employment relationships, and only few severed advising relationships, changed fund legal structure, liquidated positions, changed invest
- 2732915-021 : Among respondents answering the open ended question on other actions taken, 30.8 percent hired a compliance firm, 15.4 percent said they otherwise wasted time and money reacting to Dodd-Frank requirem
- 2732915-022 : Compliance cost is a significant issue for the private fund industry: a majority of respondents put Dodd-Frank compliance costs between $50,000 and $200,000, while a significant minority estimates tot
- 2732915-024 : The largest group of respondents, 26.5 percent, estimated annual compliance cost for all federal regulations at between $100,000 and $200,000, while a smaller group of 14.3 percent estimated it at mor
- 2732915-025 : Reported compliance time tracks reported compliance cost: a clear majority of adviser respondents spent fewer than 500 hours complying with Title IV, while a noticeable minority of 11.5 percent estima
- 2732915-026 : For all federal regulations, 65.1 percent of respondents estimate total compliance time at between 100 and 500 hours, while a noticeable minority of 20.9 percent estimate it above 1000 hours.
- 2732915-027 : Of the advisers who responded, 70.60 percent would not take the current regulatory regime into account in determining the assets under management size of their funds.
- 2732915-029 : Among advisers who factor the regulatory regime into fund sizing, the direction of adjustment is split: 18.2 percent would lower assets under management to avoid the regulatory hassle, while 27.3 perc
- 2732915-030 : A majority of respondents already took the regulatory regime into account in sizing assets under management before the Dodd-Frank Act was enacted, which implies that Dodd-Frank did not make much diffe
- 2732915-031 : The largest group of respondents prefers an assets under management size between $500 million and $1 billion, and no clear majority preference emerges around the $1.5 billion Form PF quarterly reporti
- 2732915-033 : Sixty five percent of adviser survey respondents believed that their fund earnings were not affected by the Dodd-Frank Act.
- 2732915-034 : Among the minority of respondents who believed Dodd-Frank affected fund earnings, the majority attributed that effect to additional compliance costs rather than to lower returns.
- 2732915-035 : Of those who responded, 75.4 percent indicated that the profits of their investment management company were affected by the new registration and disclosure requirements, consistent with the management
- 2732915-036 : Half of the respondents indicated that the Dodd-Frank registration and disclosure rules create higher costs that will affect their funds over the next five years, while 17.4 percent expected no effect
- 2732915-037 : Asked how Title IV will affect the private fund industry over the next five years, the largest groups of respondents identified additional expenses, at 34.9 percent, and barriers to entry for private