Investment Manager (the “Company“)
Company
Company Name
Company Address
Telephone number
*
Fax
Email
example@example.com
Website
Main Contact Person
Contact Name
Telephone number
*
Fax
E-mail Address
example@example.com
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Regulation
Is the Company authorised and/or regulated by a supervisory authority?
Yes
No
Please provide licence IDs
Names of regulatory authority:
Country of Domicile:
Date of registration:
/
Month
/
Day
Year
Date
Company registration number:
What type of funds are you licensed to manage (UCITS, UCI, AIF)?
What type of asset classes are you licensed to manage?
Is your company subject to MiFID?
Yes
No
Do you apply equivalent MiFID rules?
How do you handle external research fees
Direct payment by the Company's own funds (P&L) or
Charge the fund with a specific research fee (research payment account)?
N/A
Is your company bound by the laws and regulation of the EU or equivalent relatingto the prevention of money laundering and terrorist financing?
Yes
No
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Regulated Investment Managers
History and Direction
History of the Company
Date of incorporation
/
Month
/
Day
Year
Date
Branch offices/other locations
How was the Company founded
Important milestones
Company’s principal business
Corporate Structure
Please provide details of the Company’s current ownership structure including percentage holding.
What locations does the Company operate out of?
Have there been any changes on the ownership structure over the past 3 years?
Yes
No
Please describe the corporate and capital structure of your parent company (if applicable).
Please provide details on the composition of the Company’s Board of Directors (number of members, affiliated/independent, seniority and professional background of board members).
Please upload a document
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General
Provide a brief background of key personnel
Assets Under Management
Inception Date of the trading program
/
Month
/
Day
Year
Date
Maximum capital capacity for your trading program with current strategy, broker
Strategy
Types of instruments traded
Types of Asset Classes traded
Equities
Options
Futures
Forex
Fixed Income
ETFs
Commodities
Trading Aspect
Is your strategy ?
Automated
Semi- Automated
manual
Is it by FIX Api MT4 or MT5?
What pairs do you trade?
What time zones do you normally trade through?
Does the strategy rely on tight spreads? Or can it be traded on normal spreads?
Yes
No
How many trades does the program average per day?
What's the Average holding time?
Do you have a Circuit breaker/Throttle monitor ?
Yes
No
What's the Average trade size ?
(per $100,000 traded)
Verification
Yes
No
Are your results Audited or 3rd party verified?
Yes
No
3rd party verification link
Please upload any Trading Statements
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Strategy Approval Researcher / Client Risk controls
Max Drawdown Per Trade
Max Leverage Per Trade
Max Leverage Per Symbol
Max Leverage Total
Client Mandate
(Agreed hard stop with the client. There is always a buffer between the Hard stop to the trader and the Client Hard stop)
Position Size
Instruments traded
Yes
No
Please explain in details
Trade Parameters
Does each trade have a hard stop?
Yes
No
If so, what is the stop loss or avg stop?
Do you use basket trading?
Yes
No
Do you add to losers?
Yes
No
Previous explain
What is your risk or average risk per trade?
What is your max leverage per trade?
What is your max overall leverage?
What is the programs risk reward ratio?
Do you employ an overall equity stop?
Yes
No
Do you employ a max daily or monthly risk?
Yes
No
if so to previous, what is it?
What is the programs Max drawdown?
What is the programs max open equity drawdown?
How many trades are open at one time?
How long did it take to recover your recent 3 drawdowns?
How do you monitor pre-trade investment restrictions? Is this supported by IT systems?
Are any third parties involved in verifying adherence to risk limits? Please describe.
Staff
How many employees does the Company have for the area in scope for this due diligence questionnaire?
Headcount by department
Management
Trading
Reporting, performance analysis
PM and Research
IT/Programming
Administration
Risk Management and Compliance
Compliance
Marketing/business development
Legal
Staff change per annum
(annual turnover in %)
Portfolio Manager/Fund Ratio
Others
Have any key persons (e.g. functional/department heads) left the Company in the last 12 months?
Yes
No
Please provide separate curriculum vitae from each portfolio manager including the manager’s track record.
Rows
Name:
Years with the Company:
Responsibilities:
Portfolio manager 1
Portfolio manager 2
Portfolio manager 3
Please give details of any investment by the directors, fund managers, analysts or other employees of the Company in any product managed by the Company. Are these investments made on the same basis as external investors?
Does your Company’s Remuneration/Compensation Policy is in compliance with the remuneration requirements of Alternative Investment Fund Managers Directive (AIFMD), Capital Requirements Directive (CRD IV) or Undertakings for the Collective Investment in Transferable Securities Directive (UCITS Directive)?
Yes
No
If so, please which regulatory regime your Company is subject to/remuneration policy complies with.
Does your Company’s Remuneration/Compensation Policy is in compliance with the remuneration requirements of Alternative Investment Fund Managers Directive (AIFMD), Capital Requirements Directive (CRD IV) or Undertakings for the Collective Investment in Transferable Securities Directive (UCITS Directive)?
Yes
No
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Investment Management Activities
Product Information – General
Please provide a short description of key products (public and private, where disclosure possible) of the Company
Funds
Fund of funds
Advisory mandates
Client portfolios
Structured products
Other
Investment objective
(including target return and target risk)
Target investors
Legal structure
Current size/average size
Date of inception
/
Month
/
Day
Year
Date
Other
(If required)
Does the Company specialise in any product or group of products?
Yes
No
If so, please provide details.
Does the Company act as investment manager or investment advisor to the existing products?If investment advisor, who is the investment manager, and what function do they perform?
Investment Management Activities
Does the Company conduct any other business than investment management?Please state the nature of those other businesses.
Please provide total assets under management over the past 5 years.
Please provide a breakdown of assets under management by:
Number of funds
Track record (performance)
Client group
Country
Strategy
Which investor group does the Company primarily target?
Please provide description of the investment selection Process and how investment decisions are documented as well as the ongoing monitoring of the investments (governance structure surrounding investment decisions).
Is a pre-trade compliance policy available?
Yes
No
Please describe in detail the pre-trade compliance Process.
Could you confirm whether your pre-trade/post trade investment compliance controls/systems in place are in line with the investments objectives and restrictions of the Fund?
Yes
No
Please explain:
How many of those are automated versus manual
Which system you use
How do you address new/amended investments restrictions
Please confirm whether ex-ante and regular screening of investments is performed against applicable financial Sanctions lists? Please describe the process and systems in place and indicate which lists are used.
Please describe the processes of initial and on-going due diligence measures carried out in case of investment in assets not traded on regulated capital markets as well as on the related counterparties.
Provide details about AML/CTF training given to staff
(e.g. frequency, departments).
Do you have an asset manager rating (e.g. Fitch AMR)?
Yes
No
Which one?
Outsourcing
Does your company outsource any tasks and/or processes?
Yes
No
In case of outsourcing, please state which tasks and/or processes are outsourced to which company. Please precisely state the registered trade name (name) and registered office (address) of such company and – as far as required – whether the company is admitted to engage in asset management business. (Pls. provide copy of admission notice, if applicable).
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Have you outsourced parts of your internal control systems (e.g. risk management, internal audit, and compliance)?
Yes
No
Please describe your oversight process of the outsourced tasks and/or processes.
Please give details about your company's insurance protection with regard to the (sub-) outsourced tasks and/or processes (activity coming under insurance coverage, amount of insurance coverage, insurance company).
How do you safeguard that in case of sub-outsourcing also the subordinated outsourcer complies with the obligations applicable to you towards us and that the examination and inspection rights are safeguarded?
Please supply a list of all sub-investment managers as at today. Please give details of any changes made to sub-investment managers during the last three years and the reasons for these changes, especially if there were any concerns of malpractice, regulatory or financial failure. On the list, please indicate whether sub-investment managers are part of the same group as yours, or are independent entities.
Please detail your process for selecting sub-investment managers and thereafter monitoring their performance in accordance with the sub-investment managers’ agreement between your company and ours. In particular, please confirm that initial and ongoing due diligence on sub-investment managers has been carried out using similar guidelines to that contained in this questionnaire.
Please confirm that there is a sub-investment managers’ agreement in place with all of the sub-investment managers appointed by your company, named above, that includes the relevant articles required by the investment managers’ agreement between your company and us.
Please confirm, that these contractual agreements assure, that all sub-investment managers and their staff acting for your Company and qualifying as identified staff pursuant to ESMA Guidelines on sound remuneration policies under the UCITS Directive/AIFMD are subject to AIFMD, CRD IV or the UCITS Directive’s remuneration requirements.
Please confirm, that you have respectively will perform a recurring due diligence on your sub-investment manager verifying that the provisions of the contractual agreements are met (including remuneration policy implementation).
Please confirm that the sub-investment manager is regulated and if, under which regulator?
In case of co-managed portfolios, please briefly describe the coordinated approach to the joint management of the fund by the different co-managers. In particular, please focus thereby on the asset allocation process, the investment process, the reconciliation processes (cash, securities, receivable and liabilities), pre-trade monitoring of investment guidelines and restrictions. How are breaches handled in the co-manager set up and what are the escalation processes?
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Governance
Audit
Have there been any qualifications noted in the last audit reports? Or any exceptionsor qualifications in the control report?
Yes
No
Describe the Companies procedures and Processes including the adequate internal control mechanisms for the Effective Supervision of all business areas and employees.
How does the Company ensure the Segregation of Duties?
Investment advice
Execution of orders and administration of orders
Cash management
P&L verification
Price verification
Trade booking
Operations
Administration
Other
Please describe the measures you have implemented for maintaining security, confidentiality and integrity of our data as well as the prevention of data losses or, as the case may be, manipulation of data by unauthorized persons/parties.
Do you currently hold insurance for Directors’ & Officers’ Liability and at company’s level? What is the scope of this insurance and level of coverage?
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Regulatory/Legal/Compliance
Legal
Has there ever been any criminal, civil or administrative proceedings in which the Company and/or any of the funds, managers, advisors or any other company within the group is involved, or outsourced parties or any similar such matters including reparations, arbitrations and negotiated settlements?
Yes
No
If so, please provide details.
Regulatory
When was the last regulatory inspection, and what were the results? Did the regulator have any material comments/findings?
Have there ever been, or are there currently pending, any regulatory sanctions, against the Company, managers employed by the Company or any of the sub-managers used in the past or currently in use?
Yes
No
If so, please provide a detailed explanation.
Compliance
Please describe how compliance is structured within the Company and provide detailed organizational charts concerning compliance functions (including any functional links at Company group level, if applicable) as well as the Compliance Policy.
Does the Company have a Conflicts of Interest Policy and a conflict of interest register? Please provide a copy or give details!
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How is the Company handling any non-neutralised conflicts of interest?
Are there current or potential conflict of interest or any relationships which may affectthe Company’s trading, trading flexibility e.g. associated broker/dealers?
Does the Company have a policy aiming at securing business information and defining the necessary governance over information security?
Yes
No
Please upload policy
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Does the Company have a Customer Complaints Policy?
Yes
No
Please upload policy
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What are the Company’s employees’ own account dealing procedures (conditions for subscriptions/redemptions of fund shares)? Please give details.
What are the Company’s employees’ own account dealing procedures (conditions for subscriptions/redemptions of fund shares)? Please provide a copy
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Does the Company maintain a record of personal transactions?
Yes
No
Does the Company have an Information Barriers Policy aiming at preventing regulatory breaches with laws and regulations governing the handling and use of certain type of information, respectively the misuse of information within the Companies organization?
Yes
No
Does the Company have Regular Compliance Monitoring Programs?
Yes
No
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Administration/Operations
Process and Procedures
Does the Company have an operational “Policies and Procedures Manual”/operational flow charts?
Yes
No
Please upload policy
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Have there been any significant control incidents and/or operational losses in the last 12 months?
Yes
No
Please explain
Execution and Trading
Please describe how the Company ensures that all orders are promptly and accurately recorded and allocated and how this can be evidenced.
How trades are authorised, recorded and executed?
What are the criteria taken into account for best executing an order (e.g. price, size, …)?
What controls are in place to ensure timeliness, accuracy and completeness of trade execution?
Does the Company have an Execution Venue List/broker list? Please provide us with this list.
Is an order execution Policy Review Process implemented? How often will the policy be reviewed or updated?
Does the Company place orders to deal with other entities for execution? If yes, are best execution arrangements between the Company and the other entity in place?
Yes
No
Are best execution arrangements between the Company and the other entity in place?
"Has your Company entered into soft commission arrangements with brokers/counterparties?"
Yes
No
Please explain in detail.
Are any “soft dollars” used to pay for research or execution services?
Yes
No
How do you ensure adherence to each agreement and that soft commissions directly or indirectly benefit the corresponding account?
Does the Company have a Soft Dollar Policy? Please provide details.
Does the Company have a Soft Dollar Policy? Please provide a copy.
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What is the Company’s policy with respect to trading and system errors? Please explain in detail.
What is the company's policy with respect to pre- and post- trading incidents? Please describe the key features.
Do you confirm that your company has adequate technical infrastructure ?
IT systems & interfaces such as recording portfolio transactions
Order data and execution confirmations to the depositary bank
etc.
Please explain
What is the company's policy with respect to trades and cash reconciliation (incl. timeframe, frequency and follow up on breaks)? Please describe the key features.
What is your company's policy with respect to broker/counterparties selection and monitoring? Please describe the key features.
For non-regulated counterparties or counterparties in non-regulated markets: Do you perform AML checks on all brokers/counterparties?
Yes
No
Please explain the process.
How do you qualify and monitor asset eligibility in accordance with UCITS regulations?
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Systems
Applications
Which IT-systems are used?
Risk Management
Investment Guideline Monitoring
Operations
Reporting
Other
Infrastructure
Who supports these systems?
Are there any system changes/migrations planned in the next 2 years?
Yes
No
If yes please explain
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Disaster Recovery Procedures
Is a disaster recovery procedure or business continuity planning procedure in place?Please provide details of the Process.
How long does it take to invoke BCP and to switch on?
Please detail the frequency of the testing and its outcome. When has the plan been tested the last time and what was the outcome?
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