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This study explores lessons learned from hedge fund registration, emphasizing the effectiveness of SEC Form ADV in assessing operational risk. It examines the correlation between past legal issues and operational challenges, and introduces the ω-Score as a predictive tool for identifying potential problem funds. By analyzing 445 due diligence decisions, the research highlights the importance of transparency and trust in hedge fund investments. This work underscores the need for effective due diligence practices to mitigate risks associated with hedge funds.
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Stephen Brown, NYU William Goetzmann, Yale Bing Liang, U Mass Christopher Schwarz, UC Irvine Hedge Fund Due Diligence
Previous Work: Lessons From Hedge Fund RegistrationBrown Goetzmann Liang and Schwarz • Is SEC registration useful? • What correlates to operational risk? • Can we predict operational event?
SEC Registration Form ADV • Form ADV Item 11: legal and regulatory problems. • A “Problem” fund = a fund whose management company answered ‘Yes’ to ANY question on Item 11 of Form ADV. • Past Suspension • Past Fine • Other Legal or Regulatory issue
1526 358 Problem 1814 10295 Non-Problem Problem vs. Non-Problem Funds 100% 80% 60% 40% 20% 0% Hedge Funds All Advisers
Problems and External Conflicting Relationships **, * significant at one and five percent respectively Mandatory Disclosure and Operational Risk: Evidence from Hedge Fund Registration, Stephen Brown, William Goetzmann, Bing Laing, Christopher Schwartz, Not for reproduction or citation or quotation without authors’ permission
5 4.17 4.19 3.57 4 3.38 3 2.14 1.8 2 1.31 0.58 0.52 1 0.44 0 t-value -0.25 -1 -1.18 -1.21 -1.56 -1.56 -2 -2.15 -2.53 -3 -4 -5 -4.73 -6 Log(Assets) Fund Age Std Dev Onshore Incentive Fee High Water Relationship Direct Percent own (Years) Mark Domestic 75% Conflict of Interest and Future Performance Regression t-values. Blue = problem fund **, * significant at one and five percent respectively From Mandatory Disclosure and Operational Risk: Evidence from Hedge Fund Registration, Stephen Brown, William Goetzmann, Bing Laing, Christopher Schwartz, Draft: October 11, 2007. Not for reproduction or citation or quotation without authors’ permission
Predicting Problems • We need PAST ADV problems • Difficult to get from SEC • Instead, we can use observables • “Rotation” of Lipper-TASS variables and “Rotation” of ADV characteristics that are most highly correlated. • Canonical correlation. • Use this model with historical data.
The ω-Score: • A propensity score for “problem” • Uses TASS data (widely available) • As good as we can do without a research and due diligence team • A linear factor model • Does it predict fund disappearance? • Back-test
Operational Risk Measure Predicting Returns From Estimating Operational Risk For Hedge Funds, The Ω-Score, Stephen Brown, William Goetzmann, Bing Laing, Christopher Schwarz. Not for reproduction or citation or quotation without authors’ permission.
How About Fund Failure? • Is the half-life of the fund related to the omega score? • Other factors – age.
Operational risk and the half life of USD funds Half Life 0.7 90 months 0.6 80 0.5 70 Financial risk (prior monthly ) 0.4 0.3 60 0.2 50 0.1 40 0.8 0.4 0.6 1.0 1.2 Operational Risk -Score
Due Diligence • Market alternative to regulation • Not all funds register • Due diligence before investing
Current Study: Private Sector Data • 445 DD funds over past decade • DD decision endogenous • Past returns. • Different thresholds for problems based on returns. • Focus on honesty
Conclusion • Hedge fund opacity demands trust • Problem funds have: • Verification problems • Minor auditors • More likely to self-price