People. Your people. All those hard-working, well-meaning folks who support your firm’s marketing presentations.
And every one of them is just a fat finger away from making a last-mile mistake.
And that’s a problem for you as compliance professional. Because while to err is human, regulators don’t care. And they aren’t likely to be forgiving, either.
Consider these 2 common human-introduced data errors:
Every CCO’s worst nightmare is the unidentified compliance problem waiting to happen.
The National Society of Compliance Professionals, the Investment Adviser Association and the CFA Institute have highlighted one of them: The Last-Mile Problem. As the IAA Newsletter’s Compliance Corner noted:
“[The last-mile problem] should be on the radar of chief compliance officers at investment advisory firms. By neglecting the last mile, investment advisory firms leave themselves susceptible to a variety of very real risks in a part of their reporting process that regulators are focused on: marketing presentations.”
When it comes to submitting your firm’s data to manager databases, time is of the essence. Consultants and asset owners won’t wait for you to update your data when hundreds of other managers have timely information ready to review. In short, being late with data updates will cost you mandates.
While eVestment Omni does a great job of populating manager databases for you, it’s still up to you to submit your data on time. Manually preparing Excel files required by eVestment puts a strain on a firm’s resources at the busiest times in their reporting cycle, and can also introduce “last-mile” errors. Being late and/or inaccurate will cost you mandates from institutional clients.
Inaccurate information in manager databases raises a big red flag for consultants and asset owners reviewing your firm. In the worst case, it can take your firm out of contention for new mandates. But even minor errors—especially a pattern of errors over time—can lead to embarrassing questions during client reviews or marketing meetings, and trigger operational due diligence probes by consulting firms.
eVestment Omni does a great job of populating manager databases for you, but it’s still up to you to make sure the data you submit is accurate. Manually preparing these input Excel files can introduce “last-mile” errors that cost you mandates from institutional clients.
Did you know that some consultants are now running negative screens for missing information on their manager databases? Investment firms with holes or incomplete data elements can be eliminated from qualified searches. And saying “Whoops! Sorry, we missed that one!” won’t help. Even if you correct the omission, it can take several reporting cycles for your firm to be back in contention.
Incomplete data in manager databases is almost always the result of “last-mile” errors caused by manual or quasi-automated processes used to populate these databases.
Consultants cross-check the performance numbers and other data in your RFP responses and pitch books against what they have stored in manager databases. Manually induced inconsistencies can automatically bounce you out of qualified searches and/or open your firm up to additional operational due-diligence scrutiny.
Even if discrepancies are easily explained and corrected, the very fact that they slipped through can hurt your firm’s reputation for operational best practices.
Manager databases play a crucial role in institutional searches. Consultants and asset owners rely on manager databases to make allocation decisions.
Having up-to-date, timely, complete and accurate information about your firm in databases is a must-have to win institutional business.
Last week, we proposed three criteria you can use to assess your investment philosophy statement:
- It should be a statement of belief as opposed to process, objectives, etc.
- It should avoid logical fallacies, such as non sequiturs and mythology presented as fact.
- It should provide enough content about the philosophy itself to constitute a starting place for in-depth exploration.
Consultants and asset owners who evaluate your firm need to understand your investment philosophy. A good investment philosophy statement can help them do that by providing starting points for further conversation.
Finding out whether your investment philosophy is truly defensible requires an in-depth conversation, perhaps many conversations, as well as observation of the investment process in action. In our experience, few investment professionals can cut to the chase in these conversations. The more likely situation is that the evaluator must work to uncover the professional’s tacit knowledge, something the professional may not be able to identify or articulate without thoughtful questioning and dialogue.
One of the biggest challenges an investment firm faces is maintaining conceptual and process continuity when a key person such a founding partner or CIO leaves the firm. One of the most powerful—and least recognized—team transition tools available to investment firms is their investment philosophy. A genuinely shared investment philosophy transcends the tenure of any one individual and can be a source of stability during times of transition.