CHAPTER 16
After the Initial Allocation

ONGOING DUE DILIGENCE

Due diligence is an intelligence-gathering process in which all the information available about a fund or manager is collected, verified if possible, and analyzed. The purpose is to determine the nature and potential benefits and risks associated with the fund’s investment strategy and the structure used to access that strategy and to develop expectations about future investment activities and performance. These conclusions and expectations allow the investor to determine whether the fund is a suitable investment. However, the work does not end when an investment selection is made; due diligence is an ongoing process.
Due diligence produces information about how assets can be expected to be managed in the future. It identifies the risks associated with the managers and strategies. Steps are taken to eliminate, neutralize, or contain those risks. A variety of important factors are identified and representations are made during the due diligence process prior to investment. They form the foundation upon which future investment activity and performance expectations are based. Funds or managers are in turn selected with reliance on these expectations. If the factors change, the basis for the future expectations, and thus the investment selection, no longer exists. Therefore, the ongoing due diligence process involves keeping up with the qualitative aspects of the manager or hedge fund as well as the quantifiable aspects of the investment portfolio. How investors monitor the risk and performance of any particular allocation is partly dependent on the type, quality, and timeliness of information available based on the degree of portfolio transparency.

QUALITATIVE RISK CONTROL: HISTORIC PROBLEM AREAS

Ongoing qualitative due diligence involves periodically reviewing the various factors (often, but not always, stated as parameters), outside of investment activities and performance, that were material to selecting a manager or fund. If these have changed, the rationale for being in the investment may no longer exist. The following are some of the areas in which problems have occurred with hedge funds. As they are often repeated, it is advisable to consider them on an ongoing basis.
Assets exceed strategy capacity. Many of the hedge fund strategies profit from inefficiencies in niches of limited size. However, the high returns often attract more investor money than can be invested in the manner in which the original returns were generated. This may lead to more risky behavior by the manager to maintain return levels, such as an expansion into areas in which the manager has limited experience, or the increased use of leverage or more risky investments.
Market inefficiency no longer exists. Certain strategies capitalize on new market inefficiencies. Success attracts new investment capital and more competitors to the area. As more capital flows in, the inefficiency becomes reduced, resulting in lower returns or other changes that increase risk.
End of the trend. Many investment strategies are following and dependent on a market environment trend, such as declining interest rates. A slowdown, end, or reversal of the trend will usually adversely affect the strategy’s performance.
Latent problems. Disguised risks and exposure weaknesses may exist in a portfolio. They include concentrations that are susceptible to changes in market conditions that are not a source of return. For example, a strategy that invests in financially weak companies may have a substantial bankruptcy risk. A slight increase in the number of defaults may result in significant losses for such a strategy.
Leverage. Leveraging both magnifies the risk of the strategy and creates risk by giving the lender power over the disposition of the investment portfolio. This may occur in the form of increased margin requirements or adverse market shifts, forcing a partial or complete liquidation of the portfolio.
Change in strategy. Shifting course certainly undercuts the meaningfulness of past performance, and if the investment has already been made, the basis for investing might no longer exist. It is often a symptom of some of the other issues discussed in this section.
Exceeding stated risk parameters. This development often indicates a problem with the strategy or manager capacity.
Character/ego. Personality flaws can blind or cloud the thinking of a manager, resulting in a conscious deviation from prudent money-management activities.
Key personnel. Reliance on historical performance records and investment activities may no longer be valid if the person or persons responsible for them leaves the firm.
Fraud. Direct fraud is not common, and questionable managers can sometimes be weeded out through proper due diligence. However, fraud can only be prevented through closed system transparency where custody and control of the assets, and their valuations, are separated from the investment and trading activities. If investing in a non-transparent manner, be on the lookout for more subtle misrepresentation and material omissions, as these are often indications of deeper problems.

TRANSPARENCY

Transparency is the ability to look through a hedge fund to its underlying investment portfolio. Transparency is essential in determining whether the fund complies with and adheres to the fund’s stated investment and risk parameters and other representations made to the investor.
Investors want to be assured that they are getting the exposure and type of investment that they believe the manager sold them. This is particularly important to those with fiduciary responsibilities for investing others’ assets. In reality, many managers tend to promote a more specific investment strategy than their funds actually pursue. Most investors are aware that blind faith creates a foolhardy investment strategy. Without transparency, they can determine actual risk exposure and risk-reward prospects only from secondary sources. As discussed in Chapter 15, prudent investing requires an investigation of the specifics of a fund manager’s investment strategy, past performance, and the risk controls used to achieve the fund’s returns. Based on this information, the investor constructs a set of future expectations for performance and risk parameters to which the manager must adhere. Parameters include use of leverage, types of instruments used, exposure to asset classes and sectors, number of positions, position size, amount of hedging, and frequency of trades. For each strategy, the investor should develop general parameters, and for each manager within that strategy there should be additional, more refined, parameters. Transparency ensures that the fund or the manager can be monitored for parameter compliance.
With transparency, the risk exposures of a hedge fund investment as well as a multiple fund or manager allocation can be monitored continuously by screening the portfolio on a daily basis for compliance with the parameters established during the initial due diligence process. This approach allows the investor to ensure conformity to investment guidelines. If a parameter is breached, the violation is detected, allowing it to be addressed immediately.
The portfolio is analyzed in three ways:
1. exposures,
2. relationships, and
3. time series.
An exposure is a snapshot view of the portfolio’s contents. Exposures are analyzed to determine portfolio position concentrations, how many are long positions and how many are short, and how much leverage is being used. The second level analyzed is the relationship between the instruments: not just how much of the portfolio is long and how much short, but the relationship between the longs and the shorts. Are they matched pairs? Are they iterative constructions? Are the short positions hedges against the long? Against the market? Time series analysis examines time-dependent variables such as duration, time horizons of particular positions, and cyclical features. An example of this would be the average length of time a position is held in a risk arbitrage portfolio.
Investors use risk monitoring to confirm that each fund manager complies with the established risk parameters on a daily basis. For investors whose portfolios are allocated to more than a style manager, risk monitoring can be used to oversee the preset risk exposure of the multiple-manager composite. It allows investors to monitor whether their portfolio is diversified and risk exposure reduced, as would be expected when investment strategies are combined.
Technologies that allow for cost-effective risk management are now available, and these can be provided to investors who are afforded transparency by the managers with whom they invest. These include independent trade reconciliation, third-party pricing of the investment holdings, daily oversight of exposure limits, and active adherence to style management.

ILLUSTRATION OF RISK MONITORINGIN PRACTICE

Ongoing risk monitoring can be divided into two main areas: tactical risk monitoring and strategic risk monitoring. Tactical risk monitoring focuses on daily measures designed to ensure independent verification of positions, valuations, and exposures. Strategic risk monitoring is the periodic review of macro level factors such as performance and total portfolio risk.
The following is a step-by-step illustration of how the risk-monitoring process works. The basis for this example is the methodologies and systems developed by and used at HFR Asset Management.

DAILY TACTICAL RISK MONITORING

Once allocations are made, the portfolio is monitored daily for risk, performance, and administrative purposes. Risk monitoring involves three processes: portfolio valuation, compliance analysis, and reporting.

PORTFOLIO VALUATION

Third-party verification of positions is the key first step in the risk management process. For each investment manager who is represented in the portfolio, the previous day’s transactions, portfolio holdings, and account activities are downloaded directly from the prime broker, counterparty, or custodian with which each investment manager books trades and maintains an account. Any cash movements are verified and matched to the corresponding trade. Capital structure changes such as stock splits, distributions for reorganizations, and so forth are booked appropriately and verified with brokers.
Independent pricing is absolutely necessary. Broker pricing is often inaccurate or incomplete. In many cases, the portfolio is priced by the manager. Obviously, there has to be an independent review. Prices should be confirmed for every instrument in the portfolio by using information provided by an independent pricing data source. Closing exchange rates should be obtained to convert any securities priced in non-dollar-denominated assets for purposes of risk analysis and portfolio valuation.
In the event that a current market price is not available for a particular security, the risk monitor should obtain market pricing information from third-party sources such as market makers, brokers, and dealers. Theoretically priced instruments such as collateralized mortgage obligations, swaps, and repurchase agreements are valued by using an industry standard model. Accrued interest can be calculated using standard calculation methods developed by the Securities Industry Association.
After the portfolio is priced, the performance for that portfolio is evaluated. Any significant up or down movement at the portfolio level is then investigated and documented. Performance across a group of managers with similar strategies is evaluated for outliers.
At the conclusion of the last trade day of each month, a final confirmation and validation of market price, quantity, and market value of each investment in the account is conducted. In addition, fees and fee accruals for each account are confirmed with each fund manager.

COMPLIANCE ANALYSIS

When the portfolio valuation process is complete, each investment manager is assessed for compliance with the risk parameters that were established for the portfolio. Every risk parameter is checked against the account’s actual exposure. Compliance with each parameter is documented daily in a guideline summary report. This report identifies each risk parameter and indicates whether the parameter was violated. Every investment parameter violation will undergo an analysis on a daily basis to determine its severity. Levels of violation severity are classified to designate which violations require further investigation and/or action and specify the course of corrective action to be taken. Each violation is assigned a severity level based on previously determined risk parameters. If the violation adversely affects the risk and/or performance of the account, then the violation will be assigned a higher severity level. For a multiple hedge fund portfolio, the following severity levels might be established:

Level One

Definition. Any non-risk-increasing violation, or any instance in which a parameter is within 5 percent of being met and not otherwise determined to be a material violation or to materially increase risk (i.e., underinvestment).
Action. The violation is documented, and the violating investment manager is placed on a watch list. If the violation represents a nonmaterial increase in risk rather than a non- risk-increasing violation, the manager will be notified and the violation will be investigated within two business days. Other level one violations will be addressed with the investment managers within a reasonable period of time if these violations persist.

Level Two

Definition. Parameter violation of 5 to 10 percent that increases risk.
Action. The violation is documented, and the investment manager is contacted to investigate the violation within one business day.

Level Three

Definition. Parameter violation exceeding 10 percent, or any account activity not specifically permitted in the guidelines, or any material increase in risk.
Action. Both the investment manager and the prime broker are notified immediately to investigate violations. Corrective action may include, but is not limited to, liquidation, position offset, and reallocation of the noncompliant investment manager’s assets and removal of the investment manager from the portfolio. The client is notified within five business days of the violation and of the resultant corrective action.
Each parameter violation is ranked according to severity levels custom-designed for the portfolio. All violations are listed on the daily guideline summary report, and the appropriate level is indicated
Three levels of review are required for all guideline exceptions. A portfolio risk analyst investigates each violation and provides comment and a recommended severity level. A senior risk team leader confirms each violation and severity ranking. Finally, a member of senior management reviews the complete guideline report on a daily basis.

REPORTING PROCEDURES

In order for the daily risk management process to serve its purpose, effective reporting must be available. The following reports are typical:
1. Daily guideline summary report. This daily report lists each risk parameter for each investment manager, specifies the account’s activity in relation to the parameter, and indicates whether the parameter was violated. The report also shows the ranking for each violated parameter.
2. Daily valuation summary. This daily report provides the accurate value of the account, by both investment manager and overall portfolio. Manager summaries itemize each manager’s holdings by value of long, short, and cash positions. If valuations change for a particular account in subsequent days, a corrected report reflecting these changes is provided.
3. Monthly and quarterly performance reports. Performance reports detail each investment manager’s performance as well as the overall performance of the portfolio.
4. Customized reports. These reports are tailored to address parameters specific to a particular client or portfolio.

STRATEGIC RISK MONITORING

Whereas tactical risk monitoring focuses on a daily, quantitative process; strategic risk monitoring is concerned with a more subjective evaluation of the manager on a periodic basis. Every manager on the platform is contacted at least monthly. Confirmation of due diligence data is completed, and any significant changes discussed for clarity. The manager’s style is confirmed, and any changes in asset types, allocation levels, or risk posture are clearly understood. Specific attention should be paid to key personnel changes, persistent poor investment performance, or large growth (or decline) in a manager’s assets under management.
In addition, risk modeling tools are employed to evaluate total portfolio risk under a variety of market scenarios. Position-level transparency allows for the inclusion of all assets in quantitative modeling tools that predict the reaction of each security to market shocks. These reports provide a perspective on macro-level risks for the portfolio using measures such as value at risk. Changes in responses to market scenarios and absolute predicted risk levels over time are investigated with the manager.
Regular, monthly qualitative evaluations for each manager are prepared, and any managers who are of concern are placed on a watch list for special attention and follow-up.

SUMMARY POINTS

• Due diligence is an ongoing process.
• Factors and representations from the due diligence process form the basis for investment activity and performance expectations.
• Managers and funds are selected based on these expectations.
• If the factors change or the representations are not met, the expectations may change and, in turn, the basis for the investment with the fund or manager may no longer exist.
• Therefore, qualitative factors should be reviewed periodically and investment activities and portfolio exposures should be monitored on a daily basis for compliance with the risk parameters.
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