# Survey results

`kaal:entity:survey-results`

**Status.** derived

This node is assembled mechanically from the 58 claims that carry the concept tag `survey-results`. 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

58 claims across 3 works, 2012 to 2016.

**2012**

- [2150377-020](https://wulfkaal.github.io/claims/2150377-020) [empirical/evidenced] -- Advisers responded to Dodd-Frank registration mainly through administrative and advisory adjustments: the most common actions were outsourcing compliance work, hiring additional counsel, instituting new record keeping policies, hiring additional staff, changing marketing materials, and changing investor communications.
  > The most common actions taken include: (1) outsourced compliance work, (2) hired additional counsel, (3) instituted new record-keeping policies, (4) hired additional staff, (5) changed marketing materials, and (6) changed communications with investors.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-021](https://wulfkaal.github.io/claims/2150377-021) [empirical/evidenced] -- 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 investment styles, changed portfolio structure, or closed funds to new investors.
  > A minority of respondents: (1) severed an advising relationship, (2) changed funds' (legal) structure, (3) liquidated positions, (4) changed investment styles, (5) changed portfolio structure, or (6) closed funds to new investors.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-022](https://wulfkaal.github.io/claims/2150377-022) [empirical/evidenced] -- A majority of surveyed advisers, 72.09%, do not plan any strategic response to the Dodd-Frank Act registration and reporting requirements.
  > Figure 4.0 indicates that a majority (72.09%) of survey respondents do not plan a strategic response to the Dodd-Frank Act registration and reporting requirements.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-023](https://wulfkaal.github.io/claims/2150377-023) [empirical/evidenced] -- 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 $200,000 to over $400,000.
  > A majority of respondents found the compliance cost will range from $50,000 to $200,000. However, a significant minority estimates the total compliance cost will range from $200,000 to over $400,000.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-024](https://wulfkaal.github.io/claims/2150377-024) [empirical/evidenced] -- 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 that, so the burden distribution is skewed rather than uniform.
  > The median response was 500 hours per year. Seventy-five percent of respondents believed the federal rules would take 750 hours or less each year. On the other hand, 25% indicated the federal rules would require more than 750 hours.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-025](https://wulfkaal.github.io/claims/2150377-025) [empirical/evidenced] -- 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 their funds.
  > Of those who responded, 82.02% would not have taken the current regulatory regime into account in determining the AUM size of their funds.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-026](https://wulfkaal.github.io/claims/2150377-026) [mechanism/evidenced] -- 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 a certain size to cover the increased expenses.
  > A significant number (25%) would go smaller to avoid the regulatory hassle. A larger percentage (50%) expressed either increasing current AUM size to cover expenses or mentioned the need for a certain size in order to account for the increase in expenses.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-027](https://wulfkaal.github.io/claims/2150377-027) [empirical/evidenced] -- 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 size, while 19.54% would.
  > Of those who responded, 80.46% would not take the Form PF threshold for quarterly reporting of $1.5 billion AUM into account in determining the appropriate size of AUM for the fund(s) they manage, whereas 19.54% would take it into account.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-028](https://wulfkaal.github.io/claims/2150377-028) [mechanism/evidenced] *(failure mode)* -- 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 in assets under management, and some would close funds to new investors to do so.
  > A majority of those respondents who would take it into account plan to stay under the Form PF threshold for quarterly reporting of $1.5 billion AUM.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-029](https://wulfkaal.github.io/claims/2150377-029) [empirical/evidenced] -- 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 investors would be affected.
  > Of those who responded, 76.09% stated that their investors' rate of return has not been affected by the registration and disclosure requirements, whereas 23.91% of respondents believe their investors will be affected by the registration and disclosure requirements.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-030](https://wulfkaal.github.io/claims/2150377-030) [mechanism/argued] -- 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 costs, and whether and how those expenses will be passed to investors over time is unclear.
  > In the pool of respondents for this study, the responses seem to indicate that it is the management company that bears the brunt of costs associated with the registration and disclosure requirements. It is unclear whether and how the increased expenses will be passed on to investors over time.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-031](https://wulfkaal.github.io/claims/2150377-031) [empirical/evidenced] -- 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.
  > Of those who responded, 87.50% indicated that the profits of their investment company were affected by increased costs and decreased profits as a result of the registration and reporting requirements.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-032](https://wulfkaal.github.io/claims/2150377-032) [empirical/evidenced] -- 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 reported no strategy change.
  > Only 2.44% of respondents indicated that they would have to change their strategy significantly as a result of the registration and disclosure requirements, but 4.88% reported that the new requirements would not result in a strategy change.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-033](https://wulfkaal.github.io/claims/2150377-033) [failure/evidenced] *(failure mode)* -- 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 less attractive to new entrants.
  > Another response cluster that merits mentioning is the creation of barriers to entry for other funds because of a less attractive market environment for private funds as a result of the registration and disclosure requirements.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-034](https://wulfkaal.github.io/claims/2150377-034) [empirical/evidenced] *(failure mode)* -- 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 least $100 million because of the increased cost of compliance with the registration and disclosure requirements.
  > It used to take 25– 50 mil. to start a hedge fund in NY and then buil[d] a record and grow. Today it is at least 100 mil. [b]ecause of the increased cost of compliance with the registration and disclosure requirements.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-036](https://wulfkaal.github.io/claims/2150377-036) [empirical/argued] -- 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 environment.
  > Despite these 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 environment.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377
- [2150377-037](https://wulfkaal.github.io/claims/2150377-037) [empirical/evidenced] -- 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.
  > Firms that planned a strategic response were smaller than those firms that did not plan a strategic response.
  Wulf A. Kaal, Hedge Fund Manager Registration Under the Dodd-Frank Act (2012). SSRN: https://ssrn.com/abstract=2150377

**2014**

- [2447306-011](https://wulfkaal.github.io/claims/2447306-011) [empirical/evidenced] -- 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 the form's purpose.
  > Most advisers assert that the purpose of Form PF is to assess systemic risk and address the lack of information regarding private funds.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-012](https://wulfkaal.github.io/claims/2447306-012) [empirical/evidenced] -- 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.
  > The majority of respondents (59.18%) indicated that the total estimated cost of first time Form PF completion was under $10,000.00.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-013](https://wulfkaal.github.io/claims/2447306-013) [empirical/evidenced] -- 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 smaller funds.
  > Quarterly filing large funds spent on average $155,286 for the initial filing of Form PF. By contrast, annually filing smaller funds only spend on average $9,520 for the first time filing of Form PF.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-014](https://wulfkaal.github.io/claims/2447306-014) [empirical/evidenced] -- 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.
  > The cross-comparison suggests that the SEC may be marginally overestimating the cost of Form PF filings for both annually filing smaller private fund advisers and quarterly filing larger private fund advisers.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-015](https://wulfkaal.github.io/claims/2447306-015) [empirical/evidenced] -- 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.
  > Quarterly filing large fund advisers on average pay $72,143 for subsequent Form PF filings. Smaller private fund advertiser, on the other hand, spent only on average $5,262 for subsequent Form PF filings.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-018](https://wulfkaal.github.io/claims/2447306-018) [empirical/evidenced] -- 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 fund advisers need.
  > However, the relatively small sample of quarterly filing larger private fund advisers in this study suggest that the SEC may be overestimating the time requirements of Form PF filings for larger private fund advisers.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-019](https://wulfkaal.github.io/claims/2447306-019) [empirical/evidenced] -- 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.
  > A majority of respondents (67.35%) used only one to three individuals to complete Form PF. Similarly, a majority of respondents (69.39%) indicated that it took staff less than 50 hours to complete Form PF.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-020](https://wulfkaal.github.io/claims/2447306-020) [empirical/evidenced] -- 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 on related persons.
  > Among all Form PF questions that were identified as time-consuming, respondents indicated that Form PF Question 16 (types of investors) took the most time to answer, followed by Form PF Question 17 (performance), and Form PF Question 7 (related persons).
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-021](https://wulfkaal.github.io/claims/2447306-021) [mechanism/evidenced] -- 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 delta options and ambiguous questions or unclear instructions.
  > The majority of respondents (36%) identified "Data Gathering" as the task on which they spent the majority of their time, followed by references to "Delta Options" and "Ambiguous questions / unclear instructions".
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-022](https://wulfkaal.github.io/claims/2447306-022) [empirical/evidenced] *(failure mode)* -- 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.
  > Respondents identified the burdensome nature and the ambiguity of Form PF as the most pressing issues with Form PF.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-023](https://wulfkaal.github.io/claims/2447306-023) [empirical/evidenced] -- 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 adequate and agreed with the SEC's definitions and instructions.
  > However, the majority of respondents also considered their existing reporting systems adequate for capturing the information required by the SEC and agreed with the SEC's definitions and instructions for Form PF.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-024](https://wulfkaal.github.io/claims/2447306-024) [failure/evidenced] *(failure mode)* -- 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.
  > Several respondents suggested that the definition of leverage is inappropriately constructed and can include funds that don't use leverage or any derivative securities.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [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
- [2447306-026](https://wulfkaal.github.io/claims/2447306-026) [empirical/evidenced] -- 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.
  > A majority of respondents assessed the best level of SEC guidance in the context of their Form PF completion as sufficient or good.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-027](https://wulfkaal.github.io/claims/2447306-027) [empirical/evidenced] *(failure mode)* -- 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.
  > The majority of the commenters who believed that SEC guidance was inadequate indicated that SEC guidance was particularly unclear with respect to Form PF Section 1c, Item B (regarding Reporting Funds).
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-028](https://wulfkaal.github.io/claims/2447306-028) [empirical/evidenced] -- SEC flexibility in answering Form PF questions is valued by filers: 72.92 percent of respondents said the flexibility the SEC provides is helpful.
  > Most respondents (72.92%) agreed that the SEC's flexibility in answering questions with respect to Form PF was helpful.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-031](https://wulfkaal.github.io/claims/2447306-031) [empirical/evidenced] -- 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.
  > A majority of respondents (65.22%) stated that their existing internal reporting systems adequately capture the information required by Form PF.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-032](https://wulfkaal.github.io/claims/2447306-032) [failure/evidenced] *(failure mode)* -- 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 demand further analysis and calculation beyond what the systems already produce.
  > Several respondents (34.78%) opined that their existing internal reporting systems were insufficient to respond to questions on Form PF because they require further analysis and calculations.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-033](https://wulfkaal.github.io/claims/2447306-033) [empirical/evidenced] -- 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 exposure questions.
  > Figure 35 shows that the overwhelming majority of respondents (93.75%) did not encounter difficulties in identifying counterparties to answer Form PF questions about counterparty credit exposure.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-034](https://wulfkaal.github.io/claims/2447306-034) [empirical/argued] -- 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 appears unjustified.
  > This seems to suggest that concerns over service providers (over)interpreting required Form PF data on behalf of filers, among other concerns over service providers' completing Form PF, may not be justified.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-035](https://wulfkaal.github.io/claims/2447306-035) [failure/evidenced] *(failure mode)* -- 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 provider with the underlying information.
  > Commenters identified several challenges in working with a service-provider, including the investment of time and expenses to develop processes, and the burden of providing service-providers with the required information.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-036](https://wulfkaal.github.io/claims/2447306-036) [empirical/evidenced] -- 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.
  > Figure 38 shows that a majority of respondents (74.47%) in the sample have not been asked by their investors to provide a copy of their Form PF filing.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-037](https://wulfkaal.github.io/claims/2447306-037) [failure/evidenced] *(failure mode)* -- Form PF fund performance metrics are not accurate or comparable across filers, because reporting entities employ different calculation methodologies to produce them.
  > Several respondents mentioned Form PF Item C., Question 17 (Reporting Fund Performance), suggesting that existing Form PF fund performance metrics are not accurate because the reporting entities employ different calculation methodologies.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306
- [2447306-038](https://wulfkaal.github.io/claims/2447306-038) [design/evidenced] -- 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 total market exposure, and its total underlying capital.
  > the SEC's objective of limiting systemic risk could have been better more strongly advanced by asking questions in Form PF with an emphasis on open derivatives positions,56 total market exposure of the entity, and total underlying capital.
  Wulf A. Kaal, Private Fund Disclosures Under the Dodd-Frank Act (2014). SSRN: https://ssrn.com/abstract=2447306

**2016**

- [2732915-018](https://wulfkaal.github.io/claims/2732915-018) [empirical/evidenced] -- A majority of private fund adviser respondents, 74.5 percent, do not plan any strategic response to Title IV of the Dodd-Frank Act.
  > majority (74.5%) of private fund adviser respondents do not plan a strategic response to Title IV of the Dodd-Frank Act.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-019](https://wulfkaal.github.io/claims/2732915-019) [empirical/evidenced] -- 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, and changing communications with investors, all compliance updates rather than fundamental legal or strategic change.
  > The most common actions taken include: (1) outsourcing compliance work, (2) hiring additional counsel, (3) instituting new record-keeping policies, (4) hiring additional staff, (5) changing marketing materials, and (6) changing communications with investors.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-020](https://wulfkaal.github.io/claims/2732915-020) [empirical/evidenced] -- 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 investment styles or portfolio structure, or closed funds to new investors.
  > Private fund advisers in the sample did not terminate existing employment relationships. Few respondents severed an advising relationship, changed funds' (legal) structure, liquidated positions, changed investment styles, changed portfolio structure, or closed funds to new investors.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-021](https://wulfkaal.github.io/claims/2732915-021) [empirical/evidenced] -- 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 requirements, and 15.4 percent implemented new policies and programs.
  > 30.8% of respondents who answered this question hired a compliance firm, 15.4% suggested they otherwise wasted time and money in reacting to Dodd-Frank requirements, and 15.4 % suggested they implemented new policies and programs in response to the Dodd-Frank Act.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-022](https://wulfkaal.github.io/claims/2732915-022) [empirical/evidenced] -- 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 total compliance cost between $200,000 and over $400,000.
  > Compliance costs are a significant issue for the private fund industry. A majority of respondents found Dodd-Frank compliance costs to range from $50,000 to $200,000. However, a significant minority estimates the total compliance cost will range from $200,000 to over $400,000.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-024](https://wulfkaal.github.io/claims/2732915-024) [empirical/evidenced] -- 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 more than $400,000 a year.
  > The largest number of respondents (26.5%), however, estimated the annual compliance cost for all federal regulations at between $100,000 and $200,000. A smaller group (14.3%) estimated the cost of compliance as more than $400,000 a year.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-025](https://wulfkaal.github.io/claims/2732915-025) [empirical/evidenced] -- 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 estimated more than 1000 hours.
  > estimates pertaining to compliance time are consistent with their estimates pertaining to compliance cost. Although a clear majority of adviser respondents spent fewer than 500 hours to comply with Title IV, a noticeable minority (11.5%) estimated compliance time at more than 1000 hours.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-026](https://wulfkaal.github.io/claims/2732915-026) [empirical/evidenced] -- 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.
  > 65.1% of respondents estimate the total time required to comply with all federal regulations at between 100 and 500 hours. However, a noticeable minority (20.9%) estimate it above 1000 hours.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-027](https://wulfkaal.github.io/claims/2732915-027) [empirical/evidenced] -- 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.
  > Of those who responded, 70.60% would not take the current regulatory regime into account in determining the AUM size of their funds.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-029](https://wulfkaal.github.io/claims/2732915-029) [empirical/evidenced] -- 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 percent would still increase AUM and another 27.3 percent seek the right size to cover expenses.
  > While 18.2% would lower their AUM to avoid the regulatory hassle, 27.3% would actually still want to increase their AUM. Another 27.3% indicated a desire to attain the right size to cover expenses.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-030](https://wulfkaal.github.io/claims/2732915-030) [empirical/argued] -- 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 difference in how they run their business.
  > It shows that a majority of respondents did in fact take the regulatory regime into account before Dodd- Frank, implying that Dodd-Frank did not make much difference in the way respondents run their business.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-031](https://wulfkaal.github.io/claims/2732915-031) [empirical/evidenced] -- 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 reporting threshold.
  > Figure 13 illustrates that the largest number of respondents (33.3%) prefer an AUM size of between $500 million and $1 billion. No clear majority emerges as to the preference pertaining to the $1.5 billion Form PF quarterly reporting threshold for larger funds.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-033](https://wulfkaal.github.io/claims/2732915-033) [empirical/evidenced] -- Sixty five percent of adviser survey respondents believed that their fund earnings were not affected by the Dodd-Frank Act.
  > Figure 16 shows that 65% of adviser survey respondents believed that fund earnings were not affected by the Dodd-Frank Act.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-034](https://wulfkaal.github.io/claims/2732915-034) [empirical/evidenced] -- 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.
  > Figure 17 illustrates that the majority of those respondents who believed that Dodd-Frank affected their fund(s) earnings blamed additional compliance costs associated with Dodd-Frank.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-035](https://wulfkaal.github.io/claims/2732915-035) [empirical/evidenced] -- 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 company, rather than the fund, bearing most of those costs.
  > 75.4% indicated that the profits of their investment management company were affected. This is consistent with anecdotal evidence suggesting that it is the investment management company that bears the majority of costs associated with the registration and disclosure requirements.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-036](https://wulfkaal.github.io/claims/2732915-036) [predictive/evidenced] -- 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 and 6.5 percent expected lower returns.
  > while 17.4% believed there was no effect and 6.5% suggest the effect is lower returns, 50% indicated that the Dodd- Frank registration and disclosure rules create higher costs that affect their funds.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915
- [2732915-037](https://wulfkaal.github.io/claims/2732915-037) [empirical/evidenced] -- 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 fund market entrants, at 32.6 percent.
  > The largest numbers of respondents identified additional expenses (34.9%) and barriers to entry (32.6%) for private fund market entrants as likely effects.
  Wulf A. Kaal, The Private Fund Industry Five Years after the Dodd-Frank Act – A Survey Study (2016). SSRN: https://ssrn.com/abstract=2732915

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