Abstract
We study high-dimensional convex empirical risk minimization (ERM) under general non-Gaussian data designs. By heuristically extending the Convex Gaussian Min-Max Theorem (CGMT) to non-Gaussian settings, we derive an asymptotic min-max characterization of key statistics, enabling approximation of the mean \mu_{\hat{\theta}} and covariance C_{\hat{\theta}} of the ERM estimator \hat{\theta}. Specifically, under a concentration assumption on the data matrix and standard regularity conditions on the loss and regularizer, we show that for a test covariate x independent of the training data, the projection \hat{\theta}^\top x approximately follows the convolution of the (generally non-Gaussian) distribution of \mu_{\hat{\theta}}^\top x with an independent centered Gaussian variable of variance \text{Tr}(C_{\hat{\theta}}\mathbb{E}[xx^\top]). This result clarifies the scope and limits of Gaussian universality for ERMs. Additionally, we prove that any \mathcal{C}^2 regularizer is asymptotically equivalent to a quadratic form determined solely by its Hessian at zero and gradient at \mu_{\hat{\theta}}. Numerical simulations across diverse losses and models are provided to validate our theoretical predictions and qualitative insights.