Fund Operations - The Infrastructure Behind Investment Strategies

By EC Assets Research Team, Operational Strategy · Published · Updated

Fund Operations: Fund operations is everything a fund does apart from investing: NAV calculation, fund accounting, administration, custody, investor reporting and compliance. Operational failures, not bad trades, have closed more funds than most allocators assume, which is why due diligence starts here.

What Fund Operations Are

Fund operations are everything a fund does apart from investing: calculating net asset value, keeping investor records, processing subscriptions and redemptions, holding assets in custody, valuing hard-to-price positions, reporting to investors and regulators, managing tax and running the technology behind trading and accounting. None of it generates returns, but all of it determines whether reported returns are real.

Operational failures have closed many funds that never made a bad trade. Brown, Goetzmann, Liang and Schwarz (2008) used the disclosures hedge fund managers filed with the US Securities and Exchange Commission and found that indicators of operational risk, such as conflicts of interest and past legal problems, predicted fund failure. Most institutional investors now run operational due diligence as a separate, veto-holding step in manager selection.

How It Works

The core functions are usually split across independent providers:

Function What it covers Usual provider
Administration NAV calculation, investor register, capital flows, financial statements Independent fund administrator
Custody and financing Safekeeping of securities and cash, margin and securities lending Custodian banks and prime brokers
Audit Annual audit of financial statements and existence of assets Recognised audit firm
Valuation Policy and pricing of illiquid or hard-to-value positions Valuation committee, pricing services
Compliance and legal Regulatory filings, trading controls, fund documents Compliance officer, external counsel
Technology Order management, portfolio accounting, risk systems, investor portals Vendor systems and in-house teams

Independence between the investment team and those who value, hold and report the assets is the organising principle.

The administrator is the central control. It should receive positions and prices directly from brokers, custodians and pricing sources rather than from the manager, reconcile them, and report to investors directly. Custody arrangements, including the use of several prime brokers and limits on rehypothecation, determine what happens to assets if a provider fails.

Reconciliation ties the pieces together. Positions and cash recorded by the manager, the administrator and each broker or custodian should be matched daily, with breaks investigated and resolved promptly. Persistent unreconciled differences are one of the clearest signs that records cannot be relied on.

Worked Example

A fund with a NAV of 500 keeps 100 of assets at a single prime broker that fails. The assets are frozen for three years and eventually 95 percent is recovered. Discounting at 5 percent a year, the recovery is worth 100 × 0.95 / 1.05³ ≈ 82.06 today, a loss of about 17.94, or 17.9 percent of the frozen assets and 3.59 percent of the fund's NAV.

Had the same 100 been split equally across three prime brokers, the failure of one would have frozen about 33.3, with a loss of about 5.98, or 1.20 percent of NAV. Lehman's European insolvency in 2008 showed that such freezes can last years, which is why diversification of custody and financing became standard.

When It Applies (and Limitations)

Paper controls are not real controls. An administrator that only records numbers supplied by the manager, or an auditor without the capacity to test the existence of assets, provides little protection. Madoff's auditor was a tiny firm, a fact visible to anyone who checked, and the feeder funds that invested with him largely relied on records produced by his own firm rather than independent confirmation that the assets existed.

Valuation is the weak point. For illiquid holdings, the portfolio manager often has the best information, which creates the temptation to mark positions favourably. Independent valuation committees and pricing sources reduce, but do not remove, the risk.

Client asset segregation. The 2011 collapse of the broker MF Global revealed a shortfall in segregated customer funds, a reminder that segregation must be verified, not assumed.

Cyber and continuity risk. Payment fraud, compromised email and system outages can move or freeze money as effectively as a failed counterparty. Controls on payment instructions, call-back procedures and tested continuity plans belong in any operational review.

Operations cost money. Robust operations raise fixed costs, so small funds face a real trade-off between controls and economics; investors should treat that trade-off as a risk, not a detail.

Why It Matters for Institutional Investors

Due diligence starts here. A strategy cannot be evaluated if the returns reported for it cannot be trusted. Independent administration, custody and audit are preconditions for an allocation to any hedge fund or private vehicle, and they are part of broader due diligence.

Ongoing monitoring. Changes of administrator, auditor or key staff, delays in reporting and unusual valuation patterns are early warnings that should trigger review.

Structure and governance. Independent directors, the fund structure and the rights it gives investors affect how problems are escalated and resolved.

Transparency. Position-level or risk-level reporting delivered by the administrator, rather than by the manager, lets investors check exposures and valuations independently.

Counterparty risk. Knowing where assets are held, whether they are rehypothecated and how they would be recovered is part of measuring the true risk of an allocation.

References

  1. Brown, S., Goetzmann, W., Liang, B., & Schwarz, C. (2008). Mandatory Disclosure and Operational Risk: Evidence from Hedge Fund Registration. Journal of Finance, 63(6), 2785-2815.
  2. Brown, S., Goetzmann, W., Liang, B., & Schwarz, C. (2009). Estimating Operational Risk for Hedge Funds: The ω-Score. Financial Analysts Journal, 65(1), 43-53.
  3. U.S. Securities and Exchange Commission, Office of Inspector General. (2009). Investigation of Failure of the SEC to Uncover Bernard Madoff's Ponzi Scheme (Report No. OIG-509). SEC.
  4. Capco. (2003). Understanding and Mitigating Operational Risk in Hedge Fund Investments. Capital Markets Company.

Frequently asked questions

What are fund operations?

Everything a fund does apart from making investment decisions: calculating net asset value, keeping investor records, processing subscriptions and redemptions, holding assets in custody, valuing hard-to-price positions, reporting to investors and regulators, managing tax and running the technology that supports trading and accounting.

Why does an independent administrator matter?

Because the administrator calculates NAV and keeps investor records. If it obtains positions and prices independently, a manager cannot easily inflate returns or invent assets. Bernard Madoff's firm acted as its own broker, custodian and record keeper, which is why its fictitious statements went unchallenged for decades.

What is operational due diligence?

A review, separate from the investment assessment, of a fund's service providers, controls, valuation, segregation of duties, compliance and technology. It typically includes on-site meetings, document review and direct confirmation with administrators, custodians and auditors.

How did Lehman's collapse change fund operations?

Hedge funds whose assets sat with Lehman's European broker found them frozen in insolvency proceedings for years, partly because assets had been rehypothecated. Afterwards many funds spread assets across several prime brokers, limited rehypothecation and moved unencumbered assets to custodians.

What are common operational red flags?

A manager that calculates its own NAV, an administrator or auditor that is small, unknown or affiliated with the manager, frequent changes of service providers, investor reports that come only from the manager, weak segregation of duties and valuation policies that give the portfolio manager discretion over marks.

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