Topic 8 · ~7% Operational failure, not bad trades, kills funds

Due Diligence & Selecting Managers

Investment diligence asks whether the edge is real. Operational diligence asks whether the firm can be trusted to hold your money. The second one has the veto.

IDD vs ODD

Investment due diligence
Strategy and market opportunity; source of edge and why it persists; sourcing and origination; portfolio construction and risk management; team quality, experience and turnover; attribution of the track record to the stated process; capacity; and terms. Output: a conviction rating and a sizing recommendation.
Operational due diligence
Valuation policy and its independence; service providers (administrator, auditor, custodian, prime broker, legal); cash controls and authorisation; segregation of duties; compliance and regulatory history; technology, cyber and business continuity; firm financial viability; and governance. Output: a pass/fail.

Why the separation matters. ODD is conducted by a team independent of the investment team and holds a veto, not a vote. The reason is behavioural: an investment team that has spent months building conviction is poorly placed to walk away over a control weakness. Independent reporting lines, a documented process, and a written veto right are the examinable safeguards.

The asymmetry. Investment risk is compensated — you accept it in exchange for expected return. Operational risk is not compensated at all. Therefore the correct posture is not "price it in" but "avoid it", and a fund with an excellent strategy and a failed ODD is simply not investable at any size.

The ODD checklist

Know the categories and at least two concrete tests within each — essays reward specificity.

Valuation
Written policy; who prices what; independence of pricing from the portfolio manager; treatment of Level 2 and Level 3 assets; use of a third-party valuation agent; a valuation committee with non-investment members; consistency of methodology over time; and how side pockets, if any, are struck.
Service providers
Independent administrator performing NAV calculation and shadow accounting; a reputable auditor of appropriate size, with an unqualified opinion and consistent tenure; qualified custodian holding assets; multiple prime brokers where relevant. Verify each directly with the provider, never from the manager's marketing deck.
Cash controls
Segregation of duties between those who instruct and those who authorise; dual authorisation for transfers; restriction of transfers to pre-approved accounts; independent reconciliation; and whether anyone at the manager can move client cash unilaterally.
Compliance & legal
Registration status; regulatory examination history and findings; the compliance manual, code of ethics and personal-account dealing pre-clearance; litigation; regulatory filings consistency; and background checks on principals.
Technology & BCP
Order management and reconciliation systems; access controls; cyber posture and incident history; disaster recovery testing with a documented result; and dependence on spreadsheets for anything material.
Firm viability
Revenue relative to fixed cost, breakeven AUM, ownership structure, key-person economics and lock-ups, and whether the firm survives a 30% drawdown in AUM. A financially fragile manager makes bad decisions.

Ongoing, not one-off. ODD is repeated: annual refresh, plus triggered reviews on key-person departure, service-provider change, terms amendment, regulatory action, a valuation methodology change, or a performance pattern inconsistent with the strategy.

Red flags, ranked

Order matters — a question asking for "the most serious concern" is testing your ranking, not your ability to list.

  1. Self-administration and self-custody. The manager prices its own book, calculates its own NAV, and controls cash movement. This single configuration enabled the largest frauds in the industry's history, and it is the strongest possible signal.
  2. Unknown, undersized or affiliated auditor relative to the fund's AUM, a qualified opinion, or frequent turnover of auditor or administrator without a convincing reason.
  3. Returns implausible for the strategy. Very high Sharpe, almost no down months, and strong positive serial correlation in a supposedly liquid strategy. Smoothness is the fingerprint of either stale marks or fabricated ones.
  4. Opaque or shifting valuation policy for hard-to-value assets; no independent pricing source; methodology changes that coincide conveniently with performance.
  5. Secrecy justified as protecting the edge. Refusal to disclose positions even under NDA, to name counterparties, or to permit direct contact with service providers.
  6. Style drift. Exposures inconsistent with the mandate, or returns explained by a factor the manager claims not to run. Detect it with factor analysis, not with the manager's commentary.
  7. Key-person concentration with no succession plan, no key-person clause, and no evidence the process survives the founder.
  8. Liquidity mismatch and a gating history — fund terms more generous than the underlying assets support; previous use of gates or side pockets without clear disclosure.
  9. Rapid AUM growth beyond capacity, an incentive structure that rewards asset gathering, or a fee structure with weak alignment (no GP commitment, no high-water mark).
  10. Regulatory, litigation or reputational history, undisclosed related-party transactions, and personal-account dealing without pre-clearance.
Exam trap
The instinctive answer to "too-good-to-be-true returns" is fraud. The better answer is a diagnostic sequence: test for serial correlation, decompose the returns against a wider factor set to look for a hidden short-volatility profile, verify NAV independently with the administrator, and confirm the auditor's identity and opinion directly. Naming the tests scores; naming the suspicion does not.

Valuation & service providers

The fair-value hierarchy. Level 1 — quoted prices in active markets for identical assets. Level 2 — observable inputs other than quoted prices (comparable transactions, quoted prices in inactive markets, yield curves). Level 3 — unobservable inputs, i.e. the manager's model. Any material Level 3 exposure makes valuation governance the central diligence question, because the manager's fee, its track record and its marks all depend on the same judgement.

What good looks like: a written valuation policy approved by a body independent of the investment team; a valuation committee including non-investment members; a third-party valuation agent for Level 3 positions, engaged and paid by the fund rather than by the manager; consistent methodology applied period to period, with documented rationale for any change; and an annual audit that specifically tests valuation.

Administrator. The independent administrator should strike NAV from its own records, not merely reconcile to the manager's file — "shadow accounting" versus "manager-provided NAV" is a distinction worth stating. Confirm the administrator's scope of work directly; some engagements are far narrower than the marketing implies.

Auditor. Check that the audit firm is real, appropriately sized for the fund, and actually engaged; that the opinion is unqualified; that financial statements arrive on time; and that the audited NAV reconciles to investor statements. Historic frauds have used an audit firm with a handful of staff for a multi-billion-dollar fund — a fact discoverable in an afternoon.

Custodian and prime broker. Assets should be held by a qualified custodian, legally segregated where possible, with rehypothecation rights understood and limited. For funds using leverage, understand the financing terms, the margin methodology, and what happens on a downgrade or a market shock.

Performance persistence & selection

The evidence differs by asset class, and the nuance is the answer. For hedge funds, persistence is weak and largely disappears once returns are adjusted for risk factors and once backfill and survivorship bias are removed; what persistence exists is concentrated at short horizons and among poor performers (bad managers reliably stay bad). For private equity, persistence was historically meaningful — particularly in venture, where access to the best deals is itself the edge — but the evidence has weakened as the industry institutionalised, funds grew, and teams turned over. Never answer with a flat "past performance predicts future performance"; state the asset class, the caveats, and the mechanism.

Why raw track records mislead. Short samples give low statistical power; the same manager's numbers are contaminated by market beta in a rising market; a fund's IRR is sensitive to subscription-line use and to timing; and databases suffer selection biases in both directions. The defensible approach combines quantitative decomposition (factor exposures, PME against a like index, dispersion across the manager's own deals) with qualitative assessment (team stability, whether the people who generated the record are still there and still doing the same thing, and whether the strategy's capacity has been exceeded).

Selection alpha and the allocator's own behaviour. Manager selection has wide outcome dispersion in private markets, which is where governance attention pays. But allocators also destroy value systematically by hiring after strong performance and firing after weak performance — the documented pattern where fired managers subsequently outperform their replacements. Defences: written selection and termination criteria set in advance, a minimum evaluation horizon, and a requirement that any termination decision cite a process failure rather than a performance number.

Manager monitoring after hiring: exposures against mandate, attribution against the stated process, team and ownership changes, AUM against capacity, terms and side letters, valuation methodology, and any operational event. Define in advance what constitutes a watch-list trigger and what constitutes termination.

Ongoing monitoring & termination

Diligence does not end at funding. The exam treats monitoring as a continuous re-underwriting of the original thesis, with a pre-agreed set of events that trigger review.

Performance review
Attribute returns to the stated process. Ask whether the results came from the edge you underwrote or from a factor the manager does not claim to run. Compare against the right peer group and a factor-adjusted benchmark, not an index of convenience.
Exposure & risk review
Gross and net exposure, concentration, leverage, liquidity of the book versus liquidity of the terms, and drift in factor loadings. Style drift is easier to see in exposures than in returns.
Operational re-review
Annual re-verification of service providers, audit opinion and its timeliness, staff turnover in operations and compliance, regulatory filings and any new litigation.
Business review
AUM trend and its composition, fee revenue versus cost base, and whether the firm is viable at current AUM. Rapid growth is as concerning as decline — capacity and process strain.

Trigger events that force an immediate review rather than a scheduled one: departure of a named principal, a change of auditor or administrator, a gate or side pocket, a valuation restatement, a regulatory action, a breach of stated risk limits, a strategy or fee change, or a drawdown beyond the underwritten range.

Termination discipline. Distinguish process failure from outcome disappointment — that distinction is the answer to most essay prompts here. Terminate for a broken thesis: the edge is gone, the team that generated it has left, exposures no longer match the mandate, or operational integrity is compromised. Do not terminate solely for a drawdown consistent with the strategy's known risk profile, because selection decisions made on trailing performance are systematically procyclical. Where the concern is capacity or fit rather than integrity, consider redemption over time, a mandate change, or a move to a separately managed account before outright termination — and always document the rationale, since the alternative is a board that relitigates the decision after the next quarter.

Confusion pairs

IDD vs ODD
Is the edge real and repeatable vs can the firm be trusted with the money. ODD is independent and holds a veto.
Administrator vs custodian
Strikes the NAV and keeps the books vs holds the assets. Self-administration and self-custody are separate red flags; together they are the fraud pattern.
Level 2 vs Level 3
Observable inputs other than quoted prices vs unobservable, model-driven inputs. Level 3 requires an independent valuation process and a documented policy.
Side pocket vs gate
Illiquid positions carved out of the redeemable NAV vs a cap on total redemptions. Both restrict exit; only one segregates specific assets.
Survivorship vs backfill bias
Failed funds leave the database vs successful early track records are added retroactively. Both inflate index returns; both must be raised when a question quotes index performance.
Process failure vs bad outcome
Grounds for termination vs the normal cost of the strategy. Confusing them is the most expensive error an allocator makes.

Practice

Six multiple-choice questions in exam style, with the reasoning — not just the letter.

1. Which finding should most immediately halt an allocation, regardless of investment merit?

A. Annualised volatility below the peer median
B. The manager calculates its own NAV and can move client cash unilaterally
C. Fees above the peer median
D. AUM growth of 40% over two years
B. Self-administration combined with unilateral cash-movement authority removes the two independent checks that prevent misappropriation. It is uncompensated risk, so ODD should fail the manager outright rather than price it.

2. ODD is best positioned within an allocator's process as:

A. A weighted input to the investment team's overall score
B. An independent function with veto authority
C. A post-investment monitoring activity
D. A responsibility of the fund's administrator
B. Scoring operational risk against investment attractiveness allows a compelling strategy to outvote a control failure. Independence and a veto prevent conviction bias; ODD is also ongoing, but positioning it only post-investment (C) is far too late.

3. A liquid long/short equity fund reports a first-order autocorrelation of monthly returns of 0.45. The most appropriate interpretation is:

A. The manager has genuine short-term timing skill
B. Evidence of stale or managed marks, inconsistent with a liquid book
C. Normal for equity strategies
D. Evidence of excessive leverage
B. Liquid, marked-to-market positions should show little serial correlation. High autocorrelation implies illiquid holdings, stale pricing, or return smoothing — investigate the position-level liquidity and the independence of pricing before anything else.

4. Which statement about performance persistence is most accurate?

A. Persistence is strong and reliable across both hedge funds and private equity
B. Persistence in hedge funds is weak after risk and bias adjustment; private-equity persistence was historically stronger but has weakened
C. Persistence exists only among top-decile hedge funds
D. There is no evidence of persistence anywhere in alternatives
B. This is the nuanced position the curriculum supports. Note also that persistence among poor performers is the most robust finding in the hedge fund literature — the reliable signal is which managers to avoid.

5. A fund holds 60% of NAV in Level 3 assets. The most important governance control is:

A. Monthly investor reporting
B. A third-party valuation agent engaged by the fund and a valuation committee independent of the PM
C. A high-water mark on performance fees
D. Quarterly liquidity terms
B. With unobservable inputs, the manager's mark determines its own fee and track record. Independent valuation removes the conflict at its source; reporting frequency and fee mechanics do nothing if the underlying number is self-generated.

6. An allocator terminates managers after two weak years and hires recent top performers. Research suggests this pattern:

A. Adds value through momentum in manager skill
B. Systematically destroys value, since terminated managers often subsequently outperform their replacements
C. Is neutral once fees are considered
D. Is required by fiduciary duty
B. Return-chasing at the manager level is a documented value destroyer. The governance response is written, pre-agreed selection and termination criteria, a minimum evaluation horizon, and a requirement that terminations cite a process failure rather than recent numbers.

Constructed-response practice

Write these under time. Each outline is the shape the rubric rewards, not a model answer to memorise.

Prompt A (15 minutes). A credit fund reports 11% annualised returns with a 2.9 Sharpe ratio and two negative months in seven years. Describe the diligence you would perform before recommending an allocation, and identify the findings that would cause you to decline.

Outline:
  • Start with the statistical diagnosis, not the accusation: test serial correlation, examine the distribution's skew and kurtosis, and de-smooth to see what volatility looks like corrected.
  • Decompose returns against a full factor set including credit spread and volatility, testing explicitly for a short-option payoff profile.
  • Operational verification: confirm the administrator's scope and that it strikes NAV independently; confirm the auditor directly and check firm size and the opinion; examine the valuation policy and Level 3 share; test cash-movement controls and segregation of duties.
  • Structural review: fund liquidity terms versus asset liquidity, gating history, side pockets, leverage and financing terms.
  • Decline conditions, stated concretely: self-administration or self-custody; an auditor inadequate for the fund's size; refusal of direct contact with providers; valuation methodology changes that track performance; or unexplained smoothness that survives every benign explanation.

Prompt B (12 minutes). Explain why operational due diligence should hold a veto rather than contribute a score, and design the reporting structure and triggers you would put in place for an institution allocating to twenty hedge funds.

Outline:
  • Core argument: operational risk is uncompensated, so it cannot be traded off against expected return the way investment risk can.
  • Behavioural argument: conviction bias after months of investment work means a scored input will be overridden.
  • Structure: an ODD function reporting outside the investment team — to the CIO or risk committee — with documented pass/fail criteria and written rationale for every decision.
  • Cadence: full review pre-investment, annual refresh, and event-triggered reviews.
  • Triggers, named: key-person departure, administrator/auditor/prime-broker change, valuation methodology change, regulatory action, terms amendment, gating, and a return pattern inconsistent with the strategy.
  • Close with escalation: what happens when a trigger fires — watch list, redemption notice timing, and who decides.
← 7 · Accessing Alts 9 · Volatility & Complex Strategies →