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Every hedge fund investment manager will, at some point,
face the critical question of selecting an administrator to
whom to award the administrative mandate for the funds.
Nowadays, finding the appropriate solution to this question
is not always a straightforward task and many fund managers
struggle to identify the best possible deal. As the demand
for hedge and alternative investment products grows, so does
the need for fund administrators capable of providing innovative
outsourcing solutions and supporting increased product complexity
and sophistication.
Recent years have witnessed a rapid increase in the choices
available to hedge fund managers. Traditional financial institutions
have expanded their administrative service offerings beyond
traditional bond and equity funds. In addition, the industry
has seen the growth of independent third-party fund administrators,
specialising in supporting hedge funds and other alternative
investment products.
A low fee schedule is no longer a discriminating criterion
when selecting the most appropriate fund administrator since
the increased pressure from fund managers to reduce costs
and maximise returns has, in general, pushed administrative
fees down. The consequent compression of profit margins and
the need for greater volumes have shifted the focus of the
contest between fund administrators towards qualitative elements
of the relationship such as noteworthy expertise, diversified
capabilities, use of advanced technologies, cross-border coverage
and superior quality of services.
In this competitive and dynamic environment, the assessment
of the "fiduciary risk" component of an administration
mandate becomes a key element for the hedge fund managers
in establishing successful business relationships with their
service providers. This "fiduciary risk" can be
thought of as the fund administrator's ability to preserve
its client's trust by meeting their expectations.
In response to this need, Moody's has developed Management
Quality (MQ) ratings for administrative service providers.
MQ ratings offer fund managers a facility to enable them to
differentiate among global administrators. They also provide
administrators with a tool to meet the growing demand from
fund managers and other market participants for transparency
and disclosure. The first MQ rating to an administrator was
assigned in December 2002 to Custom House Administration &
Corporate Services Limited, a Dublin-based administrative
service provider for hedge funds.
Rating the fiduciary profile of an administrator
The objective of an MQ rating is to present third-party users
with an independent ranking of a fund administrator's ability
to provide services to clients. In other words, the rating
is an opinion of the administrator's "fiduciary risk
profile" regardless of size, ownership structure and
scope of operations.
The analytical approach supporting the MQ rating is based
on the assumption that fund administration is a fiduciary
business in which the fiduciary responsibilities extend to
every activity of the administrative mandate. An assessment
of the fiduciary risk profile of an administrator can thus
be seen as equivalent to judging the overall quality of the
organisation, its management characteristics and operational
practices.
The analytical process
The rating assessment begins with a review of the organisational
structure of the administrator. This helps identify the firm's
overall ability to exercise proper control over the diverse
activities involved in executing its obligations in a timely,
systematic and orderly manner. It is important for the fund
administrator to have adopted an organisational infrastructure
that allows it to carry out these functions without making
any serious omissions and to operate in accordance with fiduciary
standards, internal guidelines and all applicable laws and
regulations. Of course, structures may vary widely from one
fund administrator to another, ranging from the small, less
formal specialised firm operating from a single location to
the more articulated and geographically diversified organisation
serving multiple products. As a result, we adjust our analysis
to accommodate such differences.
The evaluation of the fiduciary risk profile of an administrator
also requires a review of the management's professional skills,
its record of achievements in meeting past business plans
and its level of awareness of major trends in the fund industry.
Particularly in the hedge fund business, which is characterised
by rapid products and service evolution, an assessment of
the management quality helps measure the administrator's ability
to achieve its goals, provide new services or modify existing
ones and meet customer needs on an ongoing basis.
The loss of key personnel, particularly members of senior
management and leading departmental heads, could have an adverse
effect on servicing levels. Consequently, we also evaluate
the firm's efforts to retain key staff and the potential impact
of staff departures on the stability and performance of the
firm.
Moody's analysis also endeavours to gain an understanding
of the firm's franchise, business philosophy and strategies
for development to determine its long-term feasibility.
Financial soundness is a key element in the successful operation
of service organisations. We are particularly concerned with
the administrator's ability to fund current operations and
meet capital requirements - be it systems, people or capability
to meet fiduciary responsibilities - in order to support current
and future business activities.
The MQ rating assessment places considerable emphasis on
the practices and procedures used by the administrator to
manage the business risks associated with being a fund service
provider. The review of the risk management process aims to
ensure that risks are effectively identified, evaluated, monitored
and managed at the appropriate levels within the company.
More specifically, our analysis looks at how the administrator
selects its service offerings (such as administration, accounting,
transfer agent and shareholder services, and register and
corporate secretarial services), chooses the products to support
(e.g. on-shore and off-shore conventional and hedge funds,
funds of funds, managed accounts, and investment companies)
and assesses potential clients. We also review the methods
that the administrator uses to evaluate the systems required
by personnel to service its clientele and their products in
an effective manner.
We recognise that, in an industry where pressure for automation
is strong and growing, the failure of IT operations could
threaten a company's ability to provide efficient day-to-day
operations and adequate client services. For this reason,
we also look at back-up systems and other failsafes.
Of equal relevance is the extent to which the administrator
complies with local and international regulations, which can
be ascertained by gaining an understanding of the company's
sensitivity to such compliance.
Another factor in the definition of an MQ rating is the quality
of operations and procedures. The objective here is to ascertain
that the administrator will have continued ability to administer
client assets, communicate information to clients, comply
with internal/external securities laws and regulations, and
maintain day-to-day servicing of fund portfolios. Moody's
looks at elements such as the structure and support of the
operations function, pricing practices for marketable and
non-marketable securities, valuation procedures for different
types of investment vehicles, client and regulatory/tax reporting.
We also review the hardware and software capacity in the operations,
the level of relationship with third parties (such as custodians,
prime brokers and other fund administrators), the contingency
plans and the output of internal/external audits.
Finally it is important to review client servicing in order
to measure the general quality, transparency and timeliness
of services. In general, site reviews and discussions with
senior management and other appropriate personnel help us
reach a fair opinion. We also seek access to internal information
and reports dealing with the quality and timeliness of services
and customer complaint records, along with observations of
operations and activities.
Through site visits and in-person meetings with the entire
organisation (from senior management to operational staff
involved in day-to-day operations), we make a qualitative
assessment for each component described so far. The final
rating results from a weighted combination of the different
conclusions according to the characteristics of the firm.
All of these factors are equally weighted, however, we may
modulate some to reflect the character of the firm or unit
being rated. This may be based on; the jurisdiction of the
administrator, assets under administration, number and type
of product offerings or customer types. For example, a strict
segregation of responsibilities and independence in such areas
as risk management and compliance may not be possible in a
small-sized firm with a limited number of individuals. However,
this may be offset by the type and number of products offered,
ownership structure considerations, nature of external audits,
and the firm's operations practices and procedures.
In conclusion, MQ ratings are not intended to be a substitute
for due diligence reviews by managers seeking administrative
services. The scope of Moody's opinion is to complement the
evaluations and any request-for-proposal process conducted
by asset managers. As with any other rating, the final objective
is to enable market participants to benefit from a globally
comparable analytical tool in order to increase transparency
and to communicate and improve the effectiveness of controls
and procedures in the fund administration industry.
Management Quality Rating Definitions:
Aaa(MQ)
Entities rated Aaa(MQ) are judged to exhibit an excellent
management and control environment.
Aa(MQ)
Entities rated Aa(MQ) are judged to exhibit a very good management
and control environment.
A(MQ)
Entities rated A(MQ) are judged to exhibit a good management
and control environment.
Baa(MQ)
Entities rated Baa(MQ) are judged to exhibit an adequate management
and control environment.
Ba(MQ)
Entities rated Ba(MQ) are judged to exhibit a questionable
management and control environment.
B(MQ)
Entities rated B(MQ) are judged to exhibit a poor management
and control environment.
Note: Numerical modifiers 1, 2 and 3 may be appended
to each rating classification from Aa(MQ) to B(MQ). The modifier
1 indicates that the entity ranks in the higher end of its
generic rating category; the modifier 2 indicates a mid-range
ranking; and the modifier 3 indicates that the entity ranks
in the lower end of its letter rating category.
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