Question: hedge fund managers recognize the need for improved transparency and increased self regulation. In fine with this in 2009. The Asset Managers' Committee (AMC) issued

hedge fund managers recognize the need for

hedge fund managers recognize the need for improved transparency and increased self regulation. In fine with this in 2009. The Asset Managers' Committee (AMC") issued a comprehensive Report that sets a new standard of best practices to answer the call of the President's Working Group on Financial Markets ("PWG) to reduce systemic risk and foster investor protection. This report should serve as self-regulation guidelines for hedge funds and also investors' guidelines for due diligence of hedge funds. The first key area stressed in this Report is disclosure and the greater transparency of information provided to investors. The regulatory response comes in 2011., in the form of Directive on Alternative Investment Fund Managers (AlFMs) published in the Official Journal of the European Union which aims at establishing common requirements governing the authorization and supervision of AlFMs in order to provide a coherent approach to the related risks and their impact on investors and markets in the Union". The Directive presents the huge step from fairly regulated hedge fund markets in EU towards bank-like regulation framework. Among the set of new rules regarding authorization, leverage management, supervision of a special interest for this research are transparency requirements and marketing of units or shares of EU alternative investment funds (AlFs). According to the Directive, AlFM are obliged to disclose to investors the following: description of the investment strategy and objectives of the AIF, description of the procedures by which AIF may change its investment strategy or investment policy, the identity of the AIFM, the AIF's depositary, auditor and any other service providers and a description of their duties and the investors' nights: a description of the Alf's valuation procedure and of the pricing methodology for valuing assets, including the methods used in valuing hard-to-value assets: a description of the AIF's liquidity risk management, including the redemption rights both in normal and in exceptional circumstances, and the existing redemption arrangements with investors, a description of all fees, charges and expenses and of the maximum amounts thereof which are directly or indirectly borne by investors; the latest net asset value of the AlF or its latest market price of the unit or share the identity of the prime broker and a description of any material arrangements of the Alf with its prime brokers and the way the conflicts of interest, etc By taking a closer look to regulation and the current state of hedge fund transparency, one can easily draw the parallel between new disclosure requirements and data vendors requirements, such as TASS/Tremont. Hedge Fund Research and Eurekahedge. Moreover, the decision of a hedge fund to market its shares or units is similar to decision of disseminating information through the aforementioned databanks. The analysis of databank transparency can serve as a good marker of how far away are hedge funds of prescribed disclosure policies. In addition, it illustrates the willingness of hedge fund managers to reveal certain information to potential investors. The focus of this study is to actually interpret the lack of specific information that managers omit when delivering data to databank vendors. In this aspect, we try to explain what investors can infer from the missing data that they obtain from database vendor. We concentrate on management companies managing more than thirty hedge funds while implementing different strategies Given that hedge funds are businesses, like any other type of business in order to attract clients they need to market themselves. However, since advertising in hedge fund world is not allowed the hedge fund managers can promote themselves either through the word of mouth, investors meetings, conferences, or through specialized database vendors who sell this information to qualified investors. Form the visibility point of view, releasing frequent information about their business through database vendors is the best and easiest choice for hedge fund managers. Still, the question is how accurate and transparent is the information provided in this way. Many studies have attempted to quantify the level of hedge funds transparency and database transparency, but most of them mainly focus on level of performance transparency. Anson (2002) gave an interesting comment on transparency - "Hedge fund transparency is like pornography - it is hard to describe, but you know it when you see it. For Anson there are three main reasons for which investors seek transparency. The first reason is for risk monitoring purposes, in the sense that investors want to be sure that hedge fund managers are operating within stated risk levels. The second one is the risk aggregation, so that investors can be aware of the total risk of their investment portfolio with respect to industries, economic sectors and markets. The third reason for which investors seek transparency is to see if the managers are really following the strategy they claim to apply. With respect to latter, Gibson and Gyger (2006) were investigating the style consistency in the hedge fund industry and showed that the investment style of some managers depart through time from their reported styles. Mackey and Melton (2010) analyzed if hedge funds followed their stated strategy as well. Goltz and Schroder (2010) conducted a comprehensive study of hedge fund managers and investors on current hedge fund reporting practices. They found out that from investors' point of view information disclosure was inadequate, especially disclosure regarding information about fund's liquidity and operational risk exposure. Moreover, the survey proved that 92% of all industry practitioners believe that the quality of reporting is strongly related to fund's overall quality. Liang (2003) investigated the discrepancy, and thus accuracy of hedge fund returns across different databases. He found out that audited funds had a much lower return discrepancy than non-audited funds. Bollen and Pool (2009) investigated the presence of misreporting in the hedge fund industry and demonstrated that approximately 10% of returns in the used databases were distorted. Since hedge fund reporting to database vendors is voluntary it may cause different types of database biases. Self selection bias is strongly related to manager's decision in terms of reporting to databases or not. For example if the hedge fund is well performing and wants to attract new capital, it will incline to report to database. On the other hand, if hedge fund is poorly reporting, he doesn't have an incentive to report to database. However, in many cases well established hedge funds do not want to report because they already achieved their business goals, or already have investors who want to enter the fund, or do not need additional capital. From the previous, the conclusion might be that databases tend to have average performing funds because of self-reporting bias. Aiken and al. (2010) conducted a study in which they made a comparison of the non-reporting hedge funds and reporting hedge fund performances and evidenced that on average self-reported hedge fund returns were positively biased. Grecu and al. (2007) investigated why funds stop reporting their performance data. Their findings prove that hedge fund returns significantly worsen towards the end of the reporting lives, which suggests that funds cease to report because of their poor performance. In the study we will examine the database transparency from the perspective of completeness of information provided by hedge fund managers. The focus will be on missing data in database and the reasons for their non-disclosure. This will be related to different strategic management concepts that hedge fund managers apply. The study relies on research of Lumbers (2012) in which the set up for measuring database transparency, as a percentage of non-answers with respect to total number of answers, is introduced 2. DATA AND METHODOLOGY This research is based on the data provided by Eurekahedge Europe and Eurekahedge North American hedge fund databases, as available in August 2011. At this point in time, European database of hedge funds contained 4783 funds, whereas North American database contained 5102. Each hedge fund was supposed to give information regarding basic details, fund details, management details, unique identifiers, fees and redemption schedule, industry focus, countries, service providers and profile and strategy description. The maximum number of answers for each fund is 92, but often differs across funds. For the purpose of this research we excluded data provided by Eurekahedge and also questions on which hedge fund managers cannot answer with certainty, thus ended up with 48 column variables in our research. Since the main goal of our research is to analyze the behavior and consistency of management companies with respect to their willingness to communicate their information to investors, we took the sample of companies that manage more than 30 hedge funds. The basic information about management companies and hedge funds that they manage is given in the Table 1. 142

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