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A due diligence questionnaire you do not have to join anything to get.

The two standard manager questionnaires are both behind membership. This is an original set of 69 questions in 9 sections, written to be answerable in writing and awkward to answer vaguely. Choose the sections that fit the mandate and print it. No registration, no email address, and nothing you select leaves your browser.

Choose the sections.

All 9 sections are shown below. With JavaScript enabled you can switch sections off and print only what you need. Without it, the whole questionnaire is here and prints as it stands.

69 questions in 9 sections

Reference

What each section covers.

69 questions in 9 sections. Use it to decide what to include before reading the questions themselves.

Sections of the due diligence questionnaire, the number of questions in each, and what each section is for
SectionQuestionsWhat it establishes
Firm, ownership and people8Who you would actually be dealing with, and who has an economic interest in the outcome.
Strategy and process8What the manager claims to do, in enough detail to tell whether the record could have come from it.
Portfolio construction and exposure8How individual decisions become a portfolio, and what the portfolio can look like at its extremes.
Risk management and governance8Whether risk is a function with authority, or a report produced after the fact.
Performance and reporting8Whether the record means what it appears to mean.
Operations, service providers and controls8The parts that fail quietly.
Compliance and conflicts8What the manager is obliged to do, and where its interests and yours diverge.
Terms, fees and liquidity8What you pay, what you can get back, and when.
Sustainability and stewardship5Include only where it bears on the mandate. Ask what is done, not what is believed.
Total69Across 9 sections.

Questionnaire

The questions.

Send it as it stands, or cut it down. The questions are deliberately specific: each one asks for a fact, a document or an example rather than an assurance.

Firm, ownership and people

Who you would actually be dealing with, and who has an economic interest in the outcome.

  1. Give the full legal name of the manager, the jurisdiction and date of incorporation, and every registered business name used with investors.
  2. Set out the ownership of the manager, including indirect holdings and any option or vesting arrangements that would change it.
  3. List the Australian financial services licence relied on, its number, its authorisations, and whether the manager holds it or is an authorised representative of another entity.
  4. Name every person with investment discretion, the decisions each may take alone, and what requires a second signature.
  5. For each investment decision maker, state their length of service, prior roles, and the proportion of their remuneration that varies with performance.
  6. Describe the key person risk: what happens to the portfolio and to redemptions if the principal decision maker becomes unavailable.
  7. Disclose any regulatory action, licence condition, banning order, enforceable undertaking or litigation involving the manager or its principals, whether or not concluded.
  8. State how much of the principals’ own capital is invested in the strategy, and on what terms relative to external investors.

Strategy and process

What the manager claims to do, in enough detail to tell whether the record could have come from it.

  1. Describe the strategy in terms of the economic return it is trying to capture, and why that return should persist.
  2. State the investable universe, the liquidity floor applied to it, and how a holding is removed from the universe.
  3. Explain how a position enters the portfolio: the signal or judgement, who approves it, and what is recorded at the time.
  4. Explain how a position leaves the portfolio, separating the target-reached case from the thesis-broken case from the risk-limit case.
  5. State the extent of discretion to override the process, how often that has happened, and give the most recent example.
  6. Describe every material change to the process since inception, when each was made, and what prompted it.
  7. State whether the strategy has capacity limits, how they were estimated, and what the manager will do on reaching them.
  8. If any part of the process is systematic, describe how the rules were arrived at, and how much of the record is live rather than simulated.

Portfolio construction and exposure

How individual decisions become a portfolio, and what the portfolio can look like at its extremes.

  1. State the typical and maximum number of positions, and the largest position size permitted.
  2. Describe how positions are sized, and whether sizing responds to volatility, conviction or both.
  3. State gross and net exposure limits, and the highest and lowest each has reached.
  4. State the use of leverage, its source, its cost, and the maximum employed to date.
  5. Describe the use of derivatives, the purpose of each type used, and the counterparties.
  6. State currency exposure policy: what is hedged, what is left open, and who decides.
  7. Give the concentration of the portfolio by issuer, sector, country and factor at the most recent month end.
  8. Describe how cash is managed, the typical holding, and whether cash is a residual or a position.

Risk management and governance

Whether risk is a function with authority, or a report produced after the fact.

  1. Describe the risk limits that bind the portfolio, and state which are hard and which are guidelines.
  2. State who monitors those limits, how often, and whether that person reports to the investment decision maker.
  3. Describe what happens on a breach: the escalation, the record made, and the time allowed to remedy it.
  4. List every limit breach in the last three years, with the cause and the resolution.
  5. Describe the stress tests applied to the portfolio, and give the most recent results.
  6. State how liquidity is measured at the portfolio level, and what proportion could be realised in a week under stressed conditions.
  7. Describe how positions are valued, who sets the price for anything not exchange-traded, and how that person is independent of the investment team.
  8. Describe the counterparty and custody arrangements, and what would happen to client assets on the failure of each counterparty.

Performance and reporting

Whether the record means what it appears to mean.

  1. Provide monthly returns since inception, net of all fees, with the fee assumptions used.
  2. State whether the record is of an actual account, a composite, or a representative portfolio, and identify what is excluded and why.
  3. Confirm the source of the underlying figures and whether an administrator or auditor has verified them.
  4. Identify any period in the record that is simulated, back-tested or pro forma, and label it as such.
  5. Explain every month in which the return differed materially from what the stated process would suggest.
  6. Give the largest drawdown, its duration, the time taken to recover, and what the manager changed as a result.
  7. State the benchmark used, why it is the right comparison, and whether it has changed.
  8. Describe the reporting an investor receives, its frequency, its lag, and what holdings information it contains.

Operations, service providers and controls

The parts that fail quietly.

  1. Name the administrator, auditor, custodian, prime broker and legal adviser, and state how long each has been engaged.
  2. Confirm who holds the assets and whether the manager can move cash without a second party.
  3. Describe the reconciliation between the manager’s records and the administrator’s, its frequency, and who resolves a difference.
  4. Provide the most recent audit opinion, and disclose any qualification, emphasis of matter or management letter point.
  5. Describe the trade order process from decision to settlement, and the controls at each step.
  6. State how brokers are selected, how execution quality is assessed, and whether any soft-dollar or research arrangement exists.
  7. Describe the business continuity arrangements and the last date they were tested.
  8. Describe the cyber security controls protecting investor data and payment instructions, and any incident in the last three years.

Compliance and conflicts

What the manager is obliged to do, and where its interests and yours diverge.

  1. Describe the compliance function, who performs it, and their independence from the investment team.
  2. Provide the conflicts register, or describe every conflict currently recorded in it.
  3. Describe the personal trading policy and how compliance with it is verified.
  4. State how the manager allocates a limited opportunity between accounts, and how that is evidenced.
  5. Describe every related-party transaction and every payment to an associate of the manager.
  6. State the anti-money-laundering and sanctions screening applied to investors and to counterparties.
  7. Describe the complaints and breach reporting process, and any report made to the regulator in the last three years.
  8. Confirm the professional indemnity cover held, its limit, and its exclusions.

Terms, fees and liquidity

What you pay, what you can get back, and when.

  1. Set out every fee charged, how each is calculated, and what it is charged on.
  2. State whether a performance fee is subject to a high-water mark, a hurdle, or both, and whether it crystallises before it is paid.
  3. Identify every expense borne by investors rather than the manager, and give the total expense figure for the last financial year.
  4. State the minimum investment and whether it has been waived.
  5. Describe the redemption terms: notice, frequency, settlement period and any charge.
  6. Describe every circumstance in which redemptions may be suspended, gated or paid in specie, and who decides.
  7. State whether any investor holds terms more favourable than those offered here, and describe them.
  8. Describe the tax character of distributions for an Australian investor, and who prepares the tax statements.

Sustainability and stewardship

Include only where it bears on the mandate. Ask what is done, not what is believed.

  1. State whether sustainability factors affect the investable universe, position sizing, or neither.
  2. If any exclusion applies, define it precisely enough to be tested against the holdings.
  3. Describe the data sources relied on and their coverage of the universe.
  4. Describe the voting and engagement activity undertaken in the last year, with examples.
  5. State every sustainability claim made in marketing material, and the evidence held for each.

How to use it

What to do with the answers.

A questionnaire is a way of generating things to check, not a scoring exercise. Nothing here produces a score, because a number assembled from unweighted answers would be an invention.

Read for what is missing

The informative answers are the ones that do not arrive: a limit breach history with no breaches in it, an ownership answer that stops at the holding company, a performance record with a period that is described differently from the rest. A completed questionnaire is most useful as a map of where to press.

Check the record against the process

The strategy answers describe how returns are supposed to be generated. The performance answers say what happened. Where a month is inconsistent with the stated process, that is a question, and the benchmark-relative statistics and risk ratio calculators will compute the arithmetic from the monthly series you asked for.

Test the record’s length before you weigh it

A short record cannot settle a question about skill however good it looks. Put the reported ratios through the ratio interpreter with the length of the record behind them before treating any of them as a finding.

Verify with third parties, not with the manager

Administrator, auditor and custodian answers are worth confirming directly with those firms. So is the licence: an Australian financial services licence number can be checked against the public register, including whether the manager holds it or is an authorised representative of someone else.

Limits

What this is not.

  1. It is a starting point, not a due diligence process. A questionnaire collects assertions. Due diligence is what you do with them: verification with third parties, document review, and conversations with the people who would be managing the money.
  2. It produces no score and no rating. Nothing here weights or grades an answer. A composite score built from answers of incomparable importance would look like a measurement and be an invention.
  3. It is not a standard and does not claim to be one. These questions are original to this page, written from first principles. They are not the industry questionnaires, are not derived from them, and do not substitute for them where a counterparty requires a particular form.
  4. It is not tailored to a strategy or a structure. Some sections will not apply and some mandates need questions that are not here — anything involving unlisted holdings, capital calls or a fund-of-funds structure needs more on valuation and liquidity than this covers.
  5. It is not legal or investment advice. It does not tell you what an acceptable answer is, and there is no threshold here that makes a manager suitable for any particular investor.
  6. The questions are drafted for an Australian context. Licensing and regulatory questions assume an Australian financial services licence and Australian tax reporting.
General information

This page is provided for general information only and is directed to wholesale and professional investors. It is not personal advice: it does not take into account the objectives, financial situation or needs of any person, and it is not an offer, invitation or recommendation to acquire any financial product. Investing involves risk, including the possible loss of capital.

Definitions

Terms on this page.

Each links to the glossary entry, which states the convention the term assumes as well as what it means.

Questions

Common questions.

Is this the AIMA or ILPA questionnaire?

No. Those are the industry standards, both are available to members of those organisations, and neither is reproduced or paraphrased here. This is an independent set of questions written for this page. Where a counterparty asks for a particular standard form, use that form.

Do I need to register or give an email address?

No. There is no form on this page and no request of any kind is made. The section selection and the print output are handled entirely in your browser, and nothing is transmitted, recorded or stored.

How do I get it as a document?

Use the print button, and choose “Save as PDF” in the print dialogue. The page has a print stylesheet, so the navigation, the controls and the sections you have switched off are all left out and only the questionnaire prints. To get it into a word processor, print to PDF and open that, or select the questionnaire text and copy it.

Can I add my own questions?

Not on the page, but a printed or copied questionnaire is yours to edit. Copy the text into your own document and add to it — there are no restrictions on using or adapting these questions in your own due diligence.

Which sections should I include?

Firm, strategy, risk, performance and operations apply to essentially any manager. Portfolio construction matters most where the strategy is discretionary or concentrated. Sustainability is worth including only where it bears on the mandate, since a section asking about beliefs rather than actions produces answers that cannot be checked. Terms and compliance are where the conflicts are, and they are the sections most often skipped.

Should I expect every question to be answered?

No, and the refusals are informative. Some answers are genuinely confidential, some are commercially sensitive, and a manager who declines and says why is easier to assess than one who answers everything at a level of generality that commits to nothing. What matters is whether the pattern of what is withheld makes sense.