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How does a fund of hedge funds conduct due diligence? This also applies to the ways fee investment advisers to evaluate the hedge funds into which they invest client money.

Short version: We turn over every stone, and keep turning before, during, and after an investment is made.Long version: I perform hedge fund due-diligence (DD) for family office and institutional investors so this topic is quite near and dear to me. I’m proud to have steered our clients away from several funds that turned out to either be fraudulent or blew up for operational reasons. We’re dealing with allocation sizes in the tens of millions so the stakes are obviously very high. I’ll try to be as detailed as possible but this will really only scratch the surface at best.There are several objectives to hedge fund DD (and it’s not all about making sure the manager isn't a Madoff.) It helps to recognize from the outset that each hedge fund is first and foremost a business, and for businesses to be successful they need to have a differentiated product, a repeatable process for creating that product, and as a potential client you need to evaluate your own need for the product. In other words, what is the manager's differentiating 'edge' (see Nate Anderson's answer to As a fund manager, what’s the best response to, "What is your edge?" when asked by a potential investor? I talk about the differentiated strategy approach and team experience. I’m not sure there’s a genuine structural edge in the investment business.), what is the process for exploiting that edge, and how does it fit into your portfolio?To answer these questions investors must gain a deeper understanding of all of the following: (a) the strategy, (b) the investment process, (c) the people involved in the fund, (d) the ‘business’ operations of the fund, and (e) the performance track-record.Initial ReviewTypically, the DD process starts with an initial document review to glean the basics and see if its worth taking the meeting. I generally start with the tearsheet, presentation, and recent investor letters. Every investor has their own limiting criteria, but depending on the investor some will pass right away due to factors such as:Size of the fund. Some investors want the sense of ‘safety’ from a large fund, while others prefer smaller funds due to their higher return potential. (My diligence is generally focused on smaller funds, which may have higher operational risk, so the research burden tends to be higher.)Undifferentiated strategy or an unfavorable strategy for the market environment.Lack of a track record. Many institutions and investors require 3 years of track-record or a ‘portable’ track record from a manager's previous firm in order to get comfortable with their historical ability to perform. Again, I have some investors who are comfortable being 'day-1' money which raises the due-diligence threshold.Poor relative or absolute historical performance.High volatility or large drawdowns.Poor quality of investor communication. The only thing that differentiates a 'black-box' from a transparent fund is communication. If the communication from managers is sparse or uninformative it is tough to get comfortable with a strategy. We generally like to see monthly performance updates with quarterly commentary. Anything more frequent may mean the manager is spending too much time writing, and anything less means we are in the dark for too long.Lack of credible third-party service providers (auditor, independent fund administrator, prime broker, legal counsel.) Third-party service providers are the checks and balances on a manager's operations. Investors do not get compensated for taking on unnecessary operational risks, so if we don't see auditors, administrators, and prime brokers in place we will pass immediately.MeetingIf the manager passes our initial document review we'll take a meeting. The first meeting(s) are usually the standard pitch, a walk-through of the presentation, and a high-level Q&A. Though we'll have an idea going in on what we want answered and what we'd like to discuss, we let the manager start with their pitch and always end up free-forming after a while. The idea is to get a sense of the manager, personality, and to probe on different areas of interest or concern and get a sense of whether it holds up.If the strategy, performance, fund structure, and people all pass the initial smell test and merit further interest, due-diligence begins in earnest. An initial document list is requested which generally includes:Marketing materials:Investor letters since inception. These give us a sense of the quality of communication, investment ideas, research, and insight into the manager’s personality and approach.Relevant PR such as interviews, press releases, and published articles.Due-diligence questionnaire aka the ‘DDQ’. This is a key document that asks 100+ detailed questions about the fund. The AIMA (Alternative Investment Management Association) version is the most common DDQ. We review the DDQ provided by the manager and compare it with the AIMA DDQ to see if the manager deleted any questions from the list. Usually, when a question is missing from a DDQ it's because it was irrelevant to the strategy, but sometimes a deleted question can be HIGHLY relevant and show what questions the manager doesn’t want to answer. (Here's a random completed DDQ off Google in case you’d like to get a sense of what that document looks like: Page on opcvm360.com)Research samples. Again these give us a sense of the depth and focus of the investment process.Legal:Private Placement Memorandum. This is the legal doc outlining key terms of the fund. This is generally where all the nuances on fees and fund structure are found. See How do you describe, calculate, and interpret management and incentive fees and net-of-fees returns to hedge funds? for more detail on nonsense to be aware of surrounding hedge fund fees.Subscription documents. We review to make sure everything is consistent with the PPM.Partnership agreements. These detail terms of the business structure and can also detail nuances of the fund structure.State certificate of organization/LP certificate/state registration doc, IRS W-9 tax ID form. These are mostly just confirmatory documents.Other:Audits since inception. The independent auditor’s report is of critical importance, as it will reconcile assets, portfolio balances, performance, and often provide insights on portfolio construction, liquidity of underlying assets, and back-office protocols.Independent prime brokerage report as of last completed audit. This allows us to see even more detail on the portfolio from the time of last audit and allows us to reconcile the audit with the actual portfolio. If anything doesn’t line up with the audit it means either we or the auditor are missing something.Reference list. They will all obviously be glowing references, but the choice of references can be very important. Who they leave out of the reference list is often more instructive than who is included. That being said, sometimes good information can be found through the references.Service provider contact information. We verify the relationship with each service provider, and perform due-diligence on the service providers to get an understanding of the terms and length of the relationship with the fund.Any external or internal risk reports. These give us a sense of how they measure risk, what risks they control for, and how they fall within those parameters.Regulatory registration documents such as form ADV for advisers. This is more confirmatory information but can also show critical pieces of information such as assets under management as of a particular date, key principals, number and type of clients, and compliance with the law.Once the document review is completed, you’ll likely have a better understanding (and many new questions) about key issues surrounding the 3 P’s: people, process & performance. The next step is to dig on areas of interest or concern to learn more on each of these three areas.PeopleOne of my favorite stories on manager due-diligence came from a well-known investor who passed on a hedge fund because of a raincoat:The investor wanted to get to know the manager better, so they agreed to go on a hike. Halfway up the mountain it began to downpour. Unfortunately, the manager hadn’t checked the forecast and spent the latter part of the hike completely drenched. The (dry) investor realized at that point that the manager was a little too focused on the adventure ahead of him and not at all focused on managing the predictable risks along the way. The investor passed due to concerns over risk management.We haven’t passed on any managers over rain gear, but I think the point is relevant. In poker, you must observe everything about a player; betting patterns, style of play, tolerance for risk, and personality. You piece together an understanding of the person from the data in order to get a sense of their tendencies. The same applies to due-diligence on people. Fortunately we have a lot more data to work with than at a poker table:Background checks. We use a service that looks for criminal, regulatory, and civil infractions, including Anti-Money-Laundering checks on all principals and key employees of a prospective firm.Regulatory checks. The Financial Industry Regulatory Authority (FINRA) has a very comprehensive database of brokers and investment adviser firms that shows whether individuals or firms have had any regulatory infractions, their registration status, whether they’ve had any arbitration awards issued against them, and the full employment record of registered individuals (among other things). It also ties into the SEC database which is often relevant for larger firms. All of this is obviously extremely valuable background information. One little trick we use is to match up the employment record of the principal with the bio in their marketing materials. Often they will leave firms out of their bio if they had a bad experience there, though they'll include it on their regulatory filings. It may bring up points that require further digging: BrokerCheck: Research Brokers & Investment AdvisersBack-channel reference checks. This is probably one of the hardest things to do effectively, particularly for industry outsiders, but this can be a source of absolutely critical information. This is the scuttlebutt; the “I’ll talk to my guy who worked in this manager’s Deutsche Bank division when he was a portfolio manager...” This approach is often how you get the ‘real’ story behind a manager.Regular ol’ reference checks. You have to cut through the glowing praise and ask the right questions to really get a sense of the truth, but these can be helpful.Direct interviews with the manager. This doesn’t have to be a cross examination but during the meetings there should be a component of confirmatory questions along with getting a sense of the manager’s personality, background, and approach.Google. (Never underestimate!) I was asked by a family office to diligence a manager and I googled the manager before anything. Past investors had posted on a forum that the manager lost 90%+ of their money by making risky bets then doubling down when the original bets didn’t work out.Skin in the GameAlso worth noting is that it's incredibly important to know that the manager has invested in their own fund, and that they are risking their assets alongside yours. Most investors want to know what percentage of the manager's liquid net worth is in the fund, and will often request documents to prove it.Operational and Investment ProcessNow that you understand more about the people you’re working with, you want to understand the structure and processes that constrain them.A hedge fund, like any other business, creates a product (a portfolio). In order to generate consistent portfolio performance you need to understand the sausage factory, including both the investment process AND the operational processes in place.I know what you’re thinking—operations are boring. The sexy stuff is how people come up with their brilliant investment ideas. Unfortunately, the operations and business side of the fund are not trivial matters; research has shown that over half of all hedge fund blow-ups occur due to operational issues that have nothing to do with the investment process. As unappealing as it is to try to figure out the nuances of how Net Asset Value is calculated and reconciled with the fund administrator, it’s even less appealing to lose a billion dollars because you didn’t take the time. (Yes, turning over every stone means turning over the ugly ones too.)I’ve seen institutional investors pass on funds for reasons which may not be immediately obvious problems to a new hedge fund investor. Below are some examples. If you can think through the issues or potential issues with each real-life scenario below then you are off to a good start:A small fund required a single signatory on cash transfers.A fund had legal entities for their marketing, deal sourcing, and investment divisions of the firm.A large, well-known fund has used a big-4 firm as their auditor since inception, and worked with several offices of the firm over the course of their relationship.The same fund in #3 managed their fund administration internally.A fund was down 3% one month.A fund had rehypothecation agreements in place with their Prime Broker, a major, well-respected Wall St. bank.I imagine some of the above might not even sound like English. So what does it mean and why were these all problems for the prospective investors?Single signatory. Like any other business, embezzlement can be a problem for hedge funds. Requiring a single signatory to move cash, particularly for a small fund, means that a founder/key employee can potentially loot the place without limits. It’s not unheard of for a business owner to get served divorce papers then decide it's time for an early retirement in a tropical, non-extradition friendly country. On a less major scale, an employee may embezzle smaller amounts systematically over time. Hedge funds generally have much higher asset liquidity than traditional businesses, and therefore cash stewardship is of utmost importance. For these reasons, institutions usually require double signatories on cash transfers, often with one signatory being a credible, independent fund administrator.Multiple legal entities. Separate legal entities are put in place to limit liability (and potentially transparency) between entities. Whenever a manager puts legal shields in place between different operational aspects of a fund the investor should have a very clear understanding of why that is the case. In this case the reasons didn’t pass the smell test, and were likely in place to obscure important information for investors.Using several offices of the same accountant. Accountants understand the concept of multiple legal entities all too well. For example, each office of PWC may have its own separate legal entity which protects the greater organization and other offices from shared liability. In other words, working with 3 different offices of the same firm can be like working with 3 completely different firms. Another fact about accountants: If they find a problem with a fund (or a company) they will often resign rather than report their suspicions. In this particular example, 3 offices of the same accounting firm resigned over the course of the life of the fund. Unfortunately, most investors just thought: "Well, the manager has used a credible firm since inception, therefore it’s all kosher." Wrong.In-sourced administration. Approximately 90% of all hedge fund frauds would be eliminated through use of a credible outside fund administrator to manage valuation, NAV reporting, subscriptions/redemptions, and the back-office functions of a hedge fund. Madoff (again) in-sourced his administration. He couldn’t have reasonably pulled off his fraud had he used a credible outside administrator.Fund down 3% in a month. This by itself isn’t a problem. Some funds have high volatility and +/- 5% or more in a month isn’t unusual. The problem was that this particular fund’s investment strategy was expected to generate a slow, consistent half percent a month. A drawdown in one month of 3% in the context of that strategy was a red flag. The next month the fund was down 9% and subsequently lost another 20% before shutting down.Rehypothe-what?? Rehypothecation is when the fund lends their securities to their prime broker. The broker can then use the securities as collateral to lend against, and will generally pay the fund a small fee in return, which helps lower the fund’s brokerage expenses. Here’s bottom line: When Lehman Brothers went bankrupt, this small distinction determined who 'owned' the assets. It was the difference between blow-up or solvency for many funds. (Literally billions were lost or saved over this nuanced operational detail.)In addition to operational processes, the investor must understand the investment processes in order to get a sense of how the fund’s portfolio is constructed. How does the manager source ideas, and what does their own research consist of? What kind of risks does the fund take? Risks such as currency, security, sector, market, interest rate, volatility, and countless other risks can be a part of the portfolio construction process. How does the manager make sure they are adequately compensated for those risks? How do these risks fit into the investor’s broader portfolio? Professional portfolio managers must account for all of these factors with the funds they invest.Performance.On every disclaimer on every document you will read from a hedge fund it will say: "Past performance is not indicative of future results." I'm generally not a fan of legalese but this bit should be taken as gospel. Historical returns are in the past, and without understanding them in the context of the strategy, the risks taken, and the changing nature of the strategy in the market then those returns are meaningless. Statistics lie. At the very least they can mislead: Did you know that the Vatican City has 5.9 Popes per square mile? True fact.Lets go through another quick example. If a manager tells you “we returned 100% last year.” Are you:(a) Excited(b) Interested(c) Skeptical/unsure(d) Overwhelmed by feelings of inferiority over your own lousy returnsIf the answer is anything other than lots of ‘c’ with a little bit of ‘b’ then you need to learn more about what performance means. (If your answer is ‘d’ I suggest yoga.)Performance needs to be understood in context. What risks did you take to make 100%? What is the volatility an investor can expect on those kinds of returns? (No matter how great your returns are, you only need to lose 100% once to wipe it all out.) Statistics like Sharpe ratios, maximum drawdown, correlation, and volatility can only really be helpful in the context of the market and the strategy that contributed to that performance.I once met with a manager who returned 142% in 2009 and 55% in 2010. Those were eye-popping returns, and they had all the right service providers and statistical ratios to ‘prove’ how credible and great they were.The manager told me that their whole strategy was to analyze momentum price signals, because “when you focus on one thing all day you get pretty good at it.” They were a complete black box as far as their model and their investment process, but the manager shared one aspect of the model: “When the market goes up we are able to capture those returns, but as soon as the market starts to drop, the model shuts down in order to mitigate any losses.” Classic baloney. (Explanation: Unless you know whether the market will continue to go down or up you can't determine when to turn the model on or off. He was basically implying that they could perfectly predict the direction of future price action in the market.)I passed on the fund, and it literally blew up the next month. (To be fair, I didn’t realize it would blow up so soon, though I did know that it would inevitably blow up with those returns coupled with no credible explanation of how they produced them or why they would persist.) The moral is that it's hard to find an edge and generate consistent returns, and historical performance (whether good or bad) has to be understood in full context.OverallThis overview really just scratches the surface but hopefully the framework and actionable tips are helpful. Many institutions view their due-diligence process as proprietary, but personally I’d rather see all investors have a deeper understanding of the process. It’s bad for the industry when charlatans run around with impunity, and quality diligence helps lift the entire profession. Most hedge fund managers are good people (honestly), but even among good people there can be a lot of average performers and undifferentiated strategies. A good due-diligence process can be both informative and collaborative-- in addition to learning about the managers our DD process often leads to operational improvements among funds we work with.Take your time, and don’t be afraid to ask even seemingly stupid or awkward questions. The best questions are often a little bit awkward. Always keep in mind that the next stone you turn over could be the difference between gaining or losing everything. If a manager seems reticent to provide information or answer your questions its generally a sign of what the relationship will look like going forward. Investments in hedge funds are ultimately partnerships and the good managers will understand and appreciate your need to learn before investing. Good luck!

What’s the optimal length of a CV for a job?

I am not sure that I’ve run into age discrimination, but I’m going to be 63 in March and it might be an issue some places. Now, I have experience going back to 1980 and some substantial and interesting history that will apply nicely to many new jobs, but I’ve been told that this maaaaaay be an issue.My current resume is a summary resume because, honestly, I’ve got way too many f/l jobs and books and contracts to put in a classically formatted job-based resume. I keep a chronological list of jobs for historic purposes—it’s enormously helpful to be able to say in a cover letter “I’ve done something similar for these other three companies; let me give you a few details”—and, even at 4 lines/job, it’s still 9 pages. Adding in the books and magazine articles I’ve written and it’s 17 pages. :DBut I do have a “Career Highlights” section right at the top. Rather than saying “36 years technical writing,” I say “20+ years technical writing.” The latter is true, the former is honest. Truth beats honesty in writing a resume. :)I’ve managed to boil my summary to a page and a half with the following major sections:Heading—Name (in 36pt type), a simple objective statement, city/state/zip (no street address!), email, phone, websiteCareer Highlights—things I want to call out as including career honorsExperience and Skills—I have skill sets for (in my case) Consulting, Managing, Writing, and Training. Here’s an example of what I put for Writing:Manuals, training materials, hardware and software documentation, APIs, SDKs, programming references, business and process analysis, white papers, web content, blogs, executive presentations, and books and magazine articles on technical, business, disaster preparedness, and non-technical topicsAdditional Skills—This section is for general and technical stuff that’s more baseline and doesn’t fit well in the category skills in the previous section. Here’s a sample of how that appears:General: Proposal writing, classroom training, instructional design, technical publications and project management, documentation consulting, software selection, localization, certified Scrum master, book coaching, GDPR, report design and writingTechnical: Word, Excel, PowerPoint, FrameMaker, RoboHelp, SharePoint, Access, Perforce, Bugzilla, HTML, JIRA, Acrobat, Visio, Agile, Audacity, LaTeX, SQL, SGML, relational databasesAll of this material fits on the first page, so I’m doing a great job of making my case for why someone should hire me: I’m showing a mountain of qualifications and a broad background of experiences.The second page has these sections:Selected Clients and Projects—This section lists key clients by name and then groups clients into types and mentions overall experiences. I’ve 8–10 categories and I’ll rearrange them depending on who I’m pitching to so I can subtly emphasize my skill sets for something that just happen to be what the client is looking for. Here’s a piece of the list (which I’ve formatted in a 2-column format):Financial and records software: Accounting, tax preparation, broker/financial analyst softwareMedical and health software: Medical records software, gene splicing and mapping systemsDisaster planning and business continuity: Disaster recovery analyses, system backup and recovery plans, pandemic and business continuity plansSamples—I have links to downloadable packages of samples. I’ve worked them up into general writing, technical, and managerial samples.And lo! a page and a half, easy to read, and it makes my case. I will rely on the cover letter as a way to extol more detailed virtues and the samples to back it all up. :)

My wife got a speeding ticket in Toronto, first one on the record, what should we do?

Q: first speeding ticket, Ontario, what to do—fight or pay?Well, I had a few of those during 12 years as a delivery driver in Toronto and all over Ontario. I never contested one, just paid them and used the experience to add to my local knowledge of where the speed traps area in Toronto (there are definitely certain favoured locations particularly where the speed limit is suddenly reduced and/or you are entering a school zone).As noted elsewhere, you can contest them and have a decent chance of winning, especially if you see a mistake in the ticket, or the cop doesnt come to court. You should know, however, that there was a court decision a few years ago that allowed a police officer to state in court a correction to what was written on the original ticket. This may Include the ability for them to change the charge to show how fast you were actually clocked at, if the officer (as they are permitted to do) wrote the ticket for less than the radar-indicated speed to give you a break (aka the nice-guy discount, because you are more likely to receive it if you are cooperative and respectful). So if I got a nice-guy discount I’d generally leave it at that.THE COP’S DISCRETION TO GIVE YOU A NICE-GUY DISCOUNT IS YOUR BEST FRIEND. Your best deal is they will write you up for 15 over because you will get the very tangible discount of NO DEMERIT POINTS, and end up paying about $50 instead of over $100.Regardless of how fast you were actually clocked at, If the ticket was for 16+ km over limit, the driver will receive at least 3 demerit points. They will stay on her licence for 24 months from the date of conviction, during which period she’ll want to avoid any more tickets. Your insurance company however assesses you for all convictions, including non-points offenses, for 3 years. If its a minor offence, 3 points, she can expect a slight rise in premiums.For fun I just did some stats (unfortunately I have enough tickets to provide a meaningful sample) on my own record of 6 Ontario speeding tickets over 15 years.Average actual over limit: 28.3 kmAverage over limit charge: 19kmNice guy discounts:3/6, or 4/7 including one warning (for 109 in an 80 zone, while legally passing)Additional citations rec’d during these stops: 2, both for expired documents (make sure ownership and insurance slips are up to date!)Points rec’d: 3x3=9Additional consequences: 1 MOT warning letter when I had 6 points, one problem renewing insurance (PRO TIP: find an insurance broker who knows how to negotiate with the company to keep your coverage or rating), slight boost in premiums (abour 10-15%).Ontario speeding fines are notably less draconian than in some other jurisdictions, so its rarely worthwhile contesting a minor ticket, especially one that doesnt generate any demerit points.NOTE: I deleted one comment which seemed to be promoting a certain paralegal service which contests tickets. Nothing personal, I just don’t want to be a billboard.Also, I’m happy to note I’ve been ticket-free for over four years now. Probably has something to do with no longer being a delivery driver.

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