Markdown Editor

Manager Due Diligence Report Template (IDD and ODD)

Allocator review of an external manager: firm, strategy, team, track record, risk, operations, compliance, cyber, ESG, fees, findings, conditions, own DDQ

財務・投資・会計フルERISA s.404(a); SEC Rules 206(4)-2, 206(4)-7; AIFMD Art. 19, 21; ILPA DDQ 2.0 and AIMA DDQ 2025 (names only)managerduediligencereportmath

使い方: Use it before hiring or re-approving an external investment manager. Fill the scope and the evidence log first, then rate investment and operational areas separately and turn every finding into a dated condition. The main pitfall is transcribing the manager's own questionnaire answers instead of verifying them with service providers and source data.

プレビュー

Manager Due Diligence Report: [Manager name], [Strategy or fund name]

Combined investment and operational due diligence (IDD and ODD) report written by an allocator (pension fund, endowment, fund of funds, consultant, wealth platform or family office) before hiring or re-approving an external investment manager. It records scope, the firm, strategy, team, track record, risk management, operations, compliance and regulatory history, technology and cybersecurity, responsible investment, terms and fees, findings with a rating and conditions, a monitoring plan and an original question set. It supports the prudence duty of fiduciaries such as ERISA section 404(a)(1)(B) (29 U.S.C. 1104) and product governance by distributors, as of 2026-10. Topic coverage is comparable to industry questionnaires such as the ILPA Due Diligence Questionnaire (DDQ 2.0, November 2021) and the AIMA Illustrative DDQ (2025 edition), which this template neither reproduces nor adapts; obtain them from ilpa.org and aima.org. Replace every [bracketed] value and every row marked Example. This is a document format, not financial, investment, legal or tax advice. Obtain the standard or law for the normative text.

Document control

FieldValue
Document ID[MDD-2026-014]
Manager (legal entity)[Name] (Example: Kestrel Bay Capital)
Regulatory identifiers[SEC file number / CRD / LEI / national register ID]
Product reviewed[Fund, share class or separate account strategy] (Example: Kestrel Bay Global Credit Strategy, separate account)
Review type[Initial / Annual re-review / Event-driven]
Proposed mandate size[amount] (Example: USD 75m)
Version[1.0]
Status[Draft / IC-ready / Approved / Superseded]
Owner[@lead-analyst]
Approvers/reviewers[@head-of-manager-research], [@odd-lead], [@chief-risk-officer], [@legal]
Last updatedYYYY-MM-DD
On-site or virtual visitYYYY-MM-DD, [location / video]
Data as ofYYYY-MM-DD
ClassificationConfidential (contains manager confidential information under NDA dated YYYY-MM-DD)
Reviewer independence[Statement that reviewers have no conflict with the manager, or the conflict and its mitigation]

Approvals

RoleNameDecisionDate
Head of manager research (IDD)[@name][Approve / Approve with conditions / Reject]YYYY-MM-DD
ODD lead[@name][Pass / Pass with conditions / Fail]YYYY-MM-DD
Chief risk officer[@name][Decision]YYYY-MM-DD
Investment committee[Minute reference][Decision]YYYY-MM-DD

Revision history

VersionDateAuthorChange summary
0.1YYYY-MM-DD[@name]First draft after questionnaire review
1.0YYYY-MM-DD[@name]Example: IC-ready after on-site visit and background checks
1.1YYYY-MM-DD[@name]Example: Conditions C-02 and C-03 closed; rating confirmed

Contents

1. Scope, mandate and method

ItemValue
Portfolio role[Allocation, sleeve and target weight] (Example: global credit sleeve, 5% of total portfolio, per IPS section [x])
Benchmark[Index name, currency, hedged or not]
Vehicle[Commingled fund / separate account / fund of one]
Alternatives considered[Managers screened and shortlisted, with the reason for this choice]
IDD depth[Desk review / full review with on-site]
ODD depth[Desk review / full review with on-site and service provider confirmations]
Out of scope[For example tax structuring, reviewed by external counsel]

Method used in this review:

  1. Screen the universe against the mandate criteria and record the shortlist.
  2. Send the question set in Appendix A and the document request list; receive the manager's own industry DDQ if available.
  3. Review public records: regulatory filings (for a US adviser, Form ADV Parts 1 and 2 on the SEC's Investment Adviser Public Disclosure site), court and sanctions searches, media.
  4. Analyse returns and holdings data independently (section 6).
  5. Hold meetings with the portfolio managers, the chief operating officer, the chief compliance officer and the head of risk, and observe at least one investment meeting where possible.
  6. Confirm assets, valuations and fees directly with the administrator, custodian and auditor.
  7. Score each area, record findings and conditions (section 13).

Record the depth actually achieved, not the depth planned. If the administrator would not confirm directly, or a key person was not available for interview, say so here and reflect it in the rating of the affected area.

2. Executive summary and rating

AreaRatingKey reason
Firm and stability Example3 AcceptableEmployee-owned, profitable, succession plan documented
Strategy and process Example4 StrongRepeatable credit selection with documented sell discipline
Team Example3 AcceptableExperienced lead PM; key person concentration in one analyst
Performance Example3 AcceptableNet excess return 1.1% a year over five years, with low tracking error
Risk management Example3 AcceptableIndependent risk team; liquidity stress test monthly
Operations (ODD) ExamplePass with conditionsManual reconciliation of OTC collateral (F-003)
Compliance (ODD) ExamplePassNo disciplinary events; annual review complete
Fees and terms Example3 AcceptableFee in line with peers after breakpoint
Overall ExampleRecommend hire, with conditions C-01 to C-03

Rating scale for IDD areas: 1 Unacceptable, 2 Weak, 3 Acceptable, 4 Strong, 5 Exceptional. ODD uses Pass, Pass with conditions or Fail. Define each level in your manager research policy so that ratings are comparable across reviews.

3. Firm, ownership and stability

ItemFindingEvidence
Legal entities and domicile[Entities, jurisdictions, regulators]EV-001
Ownership and control[Owners and %; voting rights; minority stakes sold to third parties]EV-002
Assets under management, firm and strategy[Five-year history, flows, client concentration]EV-003
Revenue and profitability[Break-even AUM; dependence on performance fees]EV-004
Client concentration[Largest client as % of strategy AUM]EV-003
Succession and key person plan[Documented, tested, board-approved]EV-005
Material changes in last three years[Mergers, departures, new businesses]EV-006

Example: Kestrel Bay Capital is 82% owned by eleven employees and 18% by a passive minority investor with no board seat. Firm regulatory AUM is USD 2.48bn at 2025-12-31 (matching Form ADV Part 2A Item 4.E), of which the credit strategy is USD 1.55bn; the largest client is 9% of strategy AUM. The proposed USD 75m mandate would be 75 / 1,550 = 4.8% of strategy AUM, within the 5% limit in section 13.3. Management accounts show the firm covers fixed costs at about 60% of current revenue.

4. Investment strategy and process

Cover each step, with what you observed and what evidence supports it:

StepDescriptionObserved evidenceAssessment
Universe and screening[Description][Screens, data sources][Assessment]
Research and idea generation[Description][Sample research notes][Assessment]
Decision making[Who decides, committee, vetoes][Minutes of [number] meetings][Assessment]
Portfolio construction[Position limits, sizing method, diversification][Holdings history][Assessment]
Sell discipline[Triggers, review cadence][Sold positions sample][Assessment]
Capacity[Stated capacity and how derived][Liquidity analysis][Assessment]
Style drift controls[Guidelines, pre-trade checks][Breach log][Assessment]

State how the strategy behaved in at least two contrasting market regimes and whether the explanation the manager gives matches the attribution in section 6.

5. Team and resources

Name or roleResponsibilityYears at firmYears in industryCo-investmentBackground check
[Lead portfolio manager]Final decision[n][n][Yes / No, amount band][Clear / Findings]
[Co-portfolio manager][Responsibility][n][n][Band][Result]
[Head of research][Responsibility][n][n][Band][Result]
[Head of risk]Independent risk oversight[n][n][Band][Result]

Record team turnover over five years (joiners, leavers, reasons), compensation structure (base, bonus, deferral, equity, link to long-term client returns) and the analyst coverage ratio. For each key person, state the contractual key person provision and what it triggers for clients.

6. Track record and performance analysis

6.1 Record integrity

CheckResult
Composite or fund definition and inception date[Result]
Claim of compliance with the GIPS® standards (2020 edition) and verification status[Claimed, verified by [firm] to YYYY-MM-DD / not claimed]
Portability: was the record earned at a prior firm, and by the same team?[Result]
Calculation method (time-weighted or money-weighted), fee basis (gross, net of actual or model fee)[Result]
Reconciliation of a sample of monthly returns to administrator or custodian data[Result, evidence ID]

GIPS® is a registered trademark; where the report reproduces a manager's GIPS claim, insert the notice required by its owner's trademark guidelines (see Performance Composite Report, finance/performance-composite-report). A manager's claim of compliance is its own; this review does not make any firm compliant.

6.2 Returns and risk

Conventions: USD, net of the fee schedule in section 12, calendar years, annualised figures use geometric linking.

YearStrategy net ExampleBenchmark ExampleExcess Example
20216.1%5.0%1.1%
2022-3.4%-5.2%1.8%
202311.8%10.9%0.9%
20248.0%7.1%0.9%
20257.5%6.6%0.9%
5-year annualised5.87%4.74%1.13%

Annualised return over NN years from annual returns RtR_t:

Rann=(∏t=1N(1+Rt))1/N−1R_{ann} = \left(\prod_{t=1}^{N} (1 + R_t)\right)^{1/N} - 1

Strategy: 1.061 x 0.966 x 1.118 x 1.080 x 1.075 = 1.3304, so Rann=1.33040.2−1=5.87%R_{ann} = 1.3304^{0.2} - 1 = 5.87\%. Benchmark: 1.2603, so 4.74%.

Risk-adjusted measures, with risk-free rate RfR_f, volatility σp\sigma_p, active return Rp−RbR_p - R_b and tracking error TETE (all annualised from monthly data):

Sharpe=Rp−Rfσp,IR=Rp−RbTE\text{Sharpe} = \frac{R_p - R_f}{\sigma_p}, \qquad \text{IR} = \frac{R_p - R_b}{TE}
MeasureStrategy ExampleComment
Volatility (annualised)5.2%From 60 monthly returns
Risk-free rate (average)2.8%[Bill index name]
Sharpe ratio0.59(5.87 - 2.8) / 5.2
Tracking error1.9%Versus benchmark
Information ratio0.591.13 / 1.9
Maximum drawdown-6.9%Peak 2021-12 to trough 2022-10
Up / down capture104% / 82%Versus benchmark

6.3 Attribution and consistency

Explain where excess return came from (sector or issuer selection, duration, curve, credit quality, currency, timing) using the manager's attribution and your own holdings-based check. See Performance Attribution Report (finance/performance-attribution-report) for methods. Report rolling three-year excess returns and the share of rolling periods with positive excess return; a record that depends on one year deserves a lower rating.

7. Risk management

AreaWhat to establishFindingRating
IndependenceHead of risk reports outside the investment team; can halt trading[Finding][Rating]
LimitsPosition, issuer, sector, country, duration, leverage, liquidity limits and breach handling[Finding][Rating]
MeasurementEx-ante tracking error, VaR, stress tests, factor exposures[Finding][Rating]
LiquidityAsset liquidity against redemption terms; stress test of large redemptions[Finding][Rating]
CounterpartyApproval, exposure limits, collateral (ISDA and CSA terms)[Finding][Rating]
Breach historyBreaches in the last three years and how they were resolved[Finding][Rating]

Example: Liquidity stress test assumes 25% of strategy AUM redeemed within one month; 71% of holdings can be sold within five trading days at no more than a 2% price impact under the manager's own model.

8. Operations and service providers

8.1 Trade lifecycle and controls

ProcessControl to verifyFinding
Order entry and pre-trade complianceAutomated checks against guidelines; hard and soft blocks[Finding]
Execution and allocationAllocation policy, fairness across accounts, trade errors log[Finding]
Settlement and reconciliationDaily cash and position reconciliation to custodian and prime broker[Finding]
Cash movementsDual authorisation, call-back verification, segregation from investment team[Finding]
ValuationIndependent pricing, valuation committee, override log (see Valuation Policy, compliance/valuation-policy)[Finding]
NAV and investor reportingAdministrator shadow check, error policy[Finding]

8.2 Service providers

RoleProviderTenureIndependent confirmation receivedComment
Administrator[Name][Years][Yes, YYYY-MM-DD / No][Comment]
Custodian or depositary[Name][Years][Result][Comment]
Prime broker[Name][Years][Result][Comment]
Auditor[Name][Years][Result][Opinion type, any qualifications]
Legal counsel[Name][Years][Not required]
Pricing services[Names][Years][Result]

For a US private fund relying on the audit approach under the custody rule (17 CFR 275.206(4)-2(b)(4)), confirm the auditor is PCAOB-registered and inspected and that audited financial statements reach investors within 120 days of fiscal year end. For an EU alternative investment fund, confirm the depositary appointment (AIFMD Article 21) and whether valuation is performed by an external valuer or by the AIFM with functional independence (AIFMD Article 19(4)).

9. Compliance, regulatory history and conflicts

ItemFindingEvidence
Registrations and licences[SEC registration, EU or UK authorisations, others]EV-010
Written compliance policies and annual review (for a US registered adviser, 17 CFR 275.206(4)-7)[Date of last annual review; findings and remediation]EV-011
Chief compliance officer[Name, reporting line, resources, other duties]EV-012
Code of ethics and personal trading[Pre-clearance, holdings reporting, breaches]EV-013
Regulatory examinations and correspondence[Dates, deficiency letters, responses]EV-014
Disciplinary history[Form ADV disclosures, court and sanctions searches]EV-015
Conflicts of interest[Side-by-side management, allocation, affiliated brokers, soft dollars, personal investments]EV-016
Marketing and performance presentation[Policy and review process]EV-017
AML and sanctions[Programme for investor onboarding; note: FinCEN's investment adviser AML rule has an effective date of 2028-01-01]EV-018

Related templates: Annual Compliance Review (compliance/annual-compliance-review), Investment Adviser Code of Ethics (compliance/investment-adviser-code-of-ethics), Conflicts of Interest Register (compliance/conflicts-of-interest-register), Form ADV Part 2A Brochure (compliance/form-adv-part-2a-brochure).

10. Technology, cybersecurity and business continuity

AreaWhat to establishFinding
GovernanceOwner of information security, board reporting, policies[Finding]
AssuranceIndependent assessments (penetration test, SOC 2 or ISO/IEC 27001 certification of key providers) and status of findings[Finding]
Identity and accessMFA, privileged access, joiner and leaver process[Finding]
Customer informationProgramme under applicable privacy rules (for US advisers, Regulation S-P as amended, compliance required since 2025-12-03 for larger and 2026-06-03 for smaller entities)[Finding]
Incident responsePlan, last test, client notification commitments[Finding]
Business continuityPlan, last test date, recovery time for trading and reporting[Finding]
Third-party dependencyCritical vendors and concentration (order management, data, cloud)[Finding]
AI and model useUse of AI or quantitative models in research or trading, and their governance[Finding]

11. Responsible investment

ItemFinding
Policy and governance[Policy date, owner, oversight]
Integration into process[Where ESG data enters research and sizing; examples of decisions changed]
Stewardship and engagement[Engagement log, escalation, voting where relevant]
Exclusions[List and how enforced pre-trade]
Product classification[For EU products: SFDR Article 6, 8 or 9 under Regulation (EU) 2019/2088 as in force; SFDR 2.0 (Commission proposal COM(2025) 841) is a proposal and not law as of 2026-10: the European Parliament and the Council have adopted their negotiating positions and trilogue negotiations are under way; check the current status]
Reporting and data[Metrics, coverage, estimation]
Fit with allocator policy[Fit with Responsible Investment Policy, finance/responsible-investment-policy]

12. Terms, fees and alignment

TermProposedPeer median ExampleComment
Management fee Example0.45% on first USD 50m, 0.35% above0.42%Breakpoint negotiated
Performance fee[None / rate, hurdle, high-water mark]
Pass-through expenses[List and cap]
Liquidity[Daily / monthly; notice; gates]
Most-favoured-nation clause[Yes / No]
Key person and termination rights[Terms]
Manager co-investment[Amount band]

Example fee calculation for a USD 75m mandate: 0.45% x 50m = USD 225,000; 0.35% x 25m = USD 87,500; total USD 312,500 a year, an effective rate of 312,500 / 75,000,000 = 0.417%.

Restate the five-year net return in section 6.2 using this fee schedule if the published net figures used a different fee.

13. Findings, rating and conditions

13.1 Findings register

IDAreaFindingSeverityManager responseStatus
F-001 ExampleTeamOne analyst covers 40% of holdings by value; no documented back-upMediumHiring second analyst by 2027-03-31Open
F-002 ExamplePerformance2021 to 2022 returns use a model fee higher than the actual fee charged; net returns correct but labelled inconsistentlyLowFactsheet correctedClosed
F-003 ExampleOperationsOTC collateral reconciled manually in a spreadsheet, single preparerHighMove to administrator's collateral module with four-eyes reviewOpen
F-004 ExampleCybersecurityPenetration test 14 months oldMediumNew test scheduled 2026-11Open

Severity: High (must be fixed before funding or blocks hire), Medium (condition with a date), Low (observation).

13.2 Conditions

IDConditionLinked findingDueVerified by
C-01 ExampleEvidence that collateral reconciliation runs in the administrator system with reviewF-003Before fundingODD lead
C-02 ExamplePenetration test report with no open critical findingsF-0042027-01-31ODD lead
C-03 ExampleKey person clause naming the lead PM and head of research in the investment management agreementF-001Before signingLegal

13.3 Recommendation

State the recommendation (hire, hire with conditions, watch, reject), the mandate size, any limit on allocation as a share of the manager's strategy AUM (Example: our assets no more than 5% of strategy AUM) and the date of the next review.

13.4 Writing findings and reviewing the report

Write each finding so that the investment committee can understand the risk without reading the rest of the report: state the condition you observed, the standard you expected, the evidence ID, the effect on the mandate if it is not fixed, and the manager's response. Avoid adjectives such as "robust" or "weak" without the fact behind them.

Rate severity from the effect on the allocator's clients, not from how hard the fix is. A single-preparer reconciliation of collateral (F-003) is High because an undetected break could misstate the account value and the collateral the client relies on; a stale penetration test (F-004) is Medium because the control exists but its assurance is out of date.

Before the report goes to the investment committee, a reviewer who did not take part in the diligence checks that:

  1. every rating in section 2 matches the findings and evidence in the later sections, and no area is rated without evidence;
  2. the performance figures were recomputed from source data, use the fee schedule the allocator would pay and compare like with like (currency, gross or net, benchmark hedging);
  3. service provider confirmations were received directly from the provider, not forwarded by the manager;
  4. the ODD outcome is shown separately and was not averaged into the investment rating;
  5. the proposed mandate respects the concentration limit in section 13.3 (in the example, USD 75m is 4.8% of the USD 1.55bn strategy); and
  6. each condition has an owner on both sides and a date, and the funding instruction cannot be released before the "before funding" conditions are verified.

Common errors in practice: accepting the manager's DDQ answers as evidence; leaving the background checks to the end, so that a finding arrives after the committee has met; and re-using the prior year's report text without re-testing the areas it describes. A re-review should show what changed since the last report and close or re-open each earlier finding explicitly.

14. Monitoring plan

ItemFrequencySourceTrigger for event-driven review
Performance and attributionMonthly / quarterlyManager report, custodian dataUnderperformance of more than [x]% over [period]
Holdings and guideline complianceMonthlyCustodianAny unresolved breach
Team changesAs notified, confirmed quarterlyManagerDeparture of a key person
Firm ownership and AUMQuarterlyManager, Form ADVChange of control; AUM drop over [x]%
Compliance and regulatory eventsAnnual and as notifiedManager, public recordsAny enforcement action
ODD re-reviewEvery [2] years or on triggerODD teamService provider change

15. Appendix A: Question set

IDQuestionSection
Q-FIRM-01List every owner with more than 5% economic or voting interest and any arrangement that could change control.3
Q-FIRM-02At what AUM does the firm cover its fixed costs, and what share of revenue comes from performance fees?3
Q-FIRM-03Describe the succession plan for each founder or key person and when it was last reviewed by the board.3
Q-STRAT-01Describe one recent buy and one recent sell decision, from first idea to execution, with dates and participants.4
Q-STRAT-02How was the stated strategy capacity derived, and what would you do on reaching it?4
Q-TEAM-01List all investment staff who joined or left in the last five years and the reason for each departure.5
Q-TEAM-02How is variable pay determined for portfolio managers, and how much is deferred or invested in the strategy?5
Q-PERF-01Provide monthly gross and net returns since inception, with the fee basis, and the custodian data to reconcile them.6
Q-PERF-02Which periods or positions explain most of the excess return?6
Q-RISK-01List every limit breach in the last three years, how it was detected and how it was resolved.7
Q-RISK-02Describe the liquidity stress test and its latest results.7
Q-OPS-01Map the trade lifecycle and name who can move cash, with the controls on each payment.8
Q-OPS-02Authorise us to contact your administrator, custodian and auditor directly.8
Q-OPS-03List all NAV or pricing errors in the last three years and the compensation paid.8
Q-COMP-01Provide the last annual compliance review summary and status of its findings.9
Q-COMP-02List all regulatory examinations, inquiries and litigation in the last ten years.9
Q-COMP-03How are investment opportunities allocated between accounts with different fee arrangements?9
Q-TECH-01Provide the latest independent security assessment summary and the status of its findings.10
Q-TECH-02When was the business continuity plan last tested, and what failed?10
Q-RI-01Give two examples where ESG analysis changed an investment decision.11
Q-TERMS-01List all expenses charged to clients or the fund in the last fiscal year as a percentage of AUM.12

16. Appendix B: Evidence log

Evidence IDDescriptionSourceDate receivedRetained / viewed only
EV-001 ExampleOrganisation chart and legal entity structureManager2026-08-22Retained
EV-011 ExampleAnnual compliance review summary 2025Manager2026-08-29Viewed on site only
EV-020 ExampleAdministrator confirmation of AUM and NAV processAdministrator2026-09-15Retained
EV-021 ExampleBackground check report on four key persons[Screening provider]2026-09-18Retained

Traceability check: every finding and rating in sections 3 to 12 cites an evidence ID (add an Evidence column to any table that lacks one), every finding in section 13 cites the section it came from, and every condition cites a finding.

17. Glossary and references

TermMeaning
IDDInvestment due diligence: strategy, team, process and performance
ODDOperational due diligence: operations, controls, compliance and service providers
DDQDue diligence questionnaire
AUMAssets under management
Tracking errorAnnualised standard deviation of active returns
Information ratioActive return divided by tracking error
Key person clauseContract term giving clients rights if named individuals leave
Audit approachCustody rule alternative for pooled vehicles based on annual audited financial statements

References (obtain current versions):

  • Employee Retirement Income Security Act of 1974, section 404(a) (29 U.S.C. 1104(a)), fiduciary duties.
  • 17 CFR 275.206(4)-7 (compliance procedures and practices) and 17 CFR 275.206(4)-2 (custody), eCFR.
  • Directive 2011/61/EU (AIFMD), Articles 19 and 21, EUR-Lex.
  • Regulation (EU) 2019/2088 (SFDR), EUR-Lex.
  • ILPA Due Diligence Questionnaire 2.0 (November 2021) and AIMA Illustrative DDQ for Investment Managers (2025 edition): names only.
  • GIPS standards, 2020 edition (name only).
  • Related templates: Investment Committee Memo (finance/investment-committee-memo), Investment Policy Statement (Institutional) (finance/investment-policy-statement-institutional), Performance Composite Report (finance/performance-composite-report), Valuation Policy (compliance/valuation-policy), Due Diligence Request List (finance/due-diligence-request-list).

Standard and licence note

Based on public law cited by section number: ERISA section 404(a) and SEC rules in 17 CFR Part 275 (US government works) and EU legislation from EUR-Lex (reuse with acknowledgement under Commission Decision 2011/833/EU). Structure aligned with common allocator practice for investment and operational due diligence. The ILPA DDQ 2.0, the AIMA Illustrative DDQ and the GIPS standards are cited by name only; no question, wording, ordering or layout from them is reproduced or adapted, and the question set in Appendix A is original. GIPS® is a registered trademark of its owner; insert the notice its trademark guidelines require where a GIPS claim is shown. This template is not affiliated with or endorsed by ILPA, AIMA, the GIPS standards owner or any regulator. All names and figures in the examples are fictional. This template is original text written for this collection. Check the current official versions before use. Template licence: MIT.

関連テンプレート