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Preface | p. xiii |
What Is Operational Risk? | p. 1 |
Brief History | p. 2 |
Modern Definition of Operational Risk in a Hedge Fund Context | p. 7 |
Operational Due Diligence versus Operational Risk | p. 8 |
Key Areas | p. 9 |
External Risks | p. 12 |
Internal Risks | p. 23 |
Blended Risks | p. 36 |
The Five Core Themes | p. 45 |
The Importance of Operational Due Diligence | p. 49 |
Why Should Investors Care about Operational Risk? | p. 49 |
Morton's Fork or a Hobson's Choice? | p. 50 |
Outright Fraud Still Exists | p. 51 |
Hedge Fund Fraud Cannot Be Modeled | p. 52 |
Small Discrepancies Add Up | p. 52 |
Lack of Standardized Regulation | p. 54 |
Each Hedge Fund Is Different | p. 55 |
Ability to Generate an Informational Edge | p. 56 |
Potential to Reduce Losses and Increase Returns | p. 57 |
Considering Operational Risk Factors Presents a Different View into a Firm | p. 57 |
Common Misconceptions | p. 58 |
Other Considerations: There Is Not Necessarily a Positive Correlation between Assets and Operational Quality | p. 60 |
A Study in Operational Failure: Bayou Hedge Fund Group | p. 60 |
Affiliated Broker-Dealer | p. 61 |
Large Discrepancies in the Performance of Onshore and Offshore Funds | p. 62 |
Declining Capital of Broker-Dealer | p. 63 |
Board of Directors: Members and Actions | p. 63 |
Lavish Expenses of Broker-Dealers | p. 63 |
Fake Audits Prepared by a Phony Auditor | p. 64 |
Background Questions | p. 64 |
Lack of Investor Communication | p. 64 |
Ties to People Barred from the Securities Industry | p. 65 |
Revision of Conflicted Marketing Materials | p. 66 |
Other Anomalies | p. 66 |
Who Is Qualified to Perform an Operational Due Diligence Review? | p. 69 |
Essential Skills | p. 73 |
Primary Skills | p. 74 |
Primary, Secondary, Blended, and Other Skills | p. 84 |
In-house versus Outsourcing | p. 85 |
Evolution of Independent Operational Rating Agencies | p. 86 |
Benefits of Third-Party Rating Agencies | p. 86 |
Criticisms of Third-Party Rating Agencies and Operational Due Diligence Providers | p. 87 |
Factors to Consider before Performing an Operational Review of a Hedge Fund | p. 90 |
Creating an Initial Operational Profile | p. 91 |
When Does an Operational Due Diligence Review Begin? | p. 91 |
Documentation | p. 92 |
The Pinata Problem | p. 93 |
Due Diligence Questionnaire: To Use or Not to Use? | p. 99 |
Background Investigations | p. 101 |
Other Considerations | p. 106 |
Importance of Onsite Visits | p. 107 |
Which Office to Visit | p. 108 |
Manager Interview Process | p. 109 |
What Topics Should Be Covered During an Onsite Review? | p. 111 |
Sample Topic Questions | p. 113 |
In What Order Should These Topics Be Covered? | p. 117 |
Service Provider Reviews | p. 117 |
Qualitative Operational Report: Documenting the Operational Data | p. 119 |
Evaluating the Gray Areas: Examples | p. 121 |
"It Was Not Me"-Hedge Fund Manager Claims Mistaken Identity | p. 121 |
"It Was Me, But Everyone Was Doing It"-Are Regulatory Witch Hunts Real? | p. 123 |
"It Was Me, But I Did Nothing Wrong"-Manager Proved Not Guilty | p. 127 |
The Low-Profile Hedge Fund Manager-Is No News Good News? | p. 129 |
The Infrastructure Outsourcer-Can One Administrator Do Everything? | p. 135 |
The Mountain Climber-Can Plans for Large, Fast Growth Trip You Along the Way? | p. 137 |
The Stumbling Giant-Can a Large Manager Lose Sight of Small Controls? | p. 140 |
The Apologetic Headmaster-Are Junior Staff as Informed as Senior Management? | p. 143 |
Ten Tips for Performing an Operational Due Diligence Review | p. 145 |
Avoid Meeting with the Wrong People or the Wrong Groups | p. 146 |
Get Out of the Conference Room | p. 147 |
Little White Lies Can Turn into Big Problems | p. 149 |
Be Wary of Phantomware | p. 151 |
Focus on Documentation and Negotiation | p. 153 |
Read the Fine Print (Financial Statement Notes, etc.) | p. 154 |
Reference Checking: Importance of In-Sample and Out-of-Sample References | p. 156 |
Credit Analysis: Are Funds Financially Viable? | p. 157 |
Long-Term Planning: Key Staff Retention, Succession Planning, and More | p. 157 |
Growth Planning: Is the Manager Proactive or Reactive? | p. 158 |
Ongoing Operational Profile Monitoring | p. 161 |
How Often Should Onsite Operational Reviews Be Conducted? | p. 163 |
Remote Operational Due Diligence Monitoring | p. 164 |
Media Monitoring | p. 164 |
Litigation and Regulatory Monitoring | p. 166 |
Hedge Fund Communication Reviews | p. 166 |
Assets Under Management and Performance Monitoring | p. 167 |
Operational Events | p. 168 |
Effect of Discovery on the Magnitude of an Operational Event | p. 169 |
Onsite Visit Frequency and Operational Events | p. 169 |
Developmental Operational Traps | p. 169 |
Techniques for Modeling Operational Risk | p. 179 |
Scoring Systems | p. 179 |
Building a Scoring System: Category Determination | p. 179 |
Category Definitions | p. 185 |
Combinations of Category Definition Approaches | p. 189 |
Category Weight Assignment | p. 193 |
Weighting Aggregation Model | p. 195 |
Weighting Disaggregation Model | p. 197 |
WAM versus WDM | p. 200 |
Category Weight Consistency and Reweighting Considerations | p. 201 |
Factor Marginalization | p. 202 |
Category Scale Determination and the Meaning of Scores | p. 203 |
Threshold Self-Assessment and Determination | p. 204 |
Score Assignment | p. 206 |
Discretionary Penalties and Bonuses | p. 212 |
Score Aggregation: Sum Totaling and Weighted Averages | p. 214 |
Criticisms of Scorecard Models | p. 215 |
Benefits of Scorecard Models | p. 217 |
Visualization Techniques | p. 217 |
Bridging the Gap: Incorporating Operational Risk Consideration into the Portfolio Construction and Asset Allocation Process | p. 225 |
Proactive Monitoring: Graphical Universe Creation | p. 227 |
Proactive Management of Operational Risks | p. 232 |
Protecting against Conglomeration Risks: Multivariate Commonality Analysis | p. 233 |
Operational Directional Views | p. 235 |
Example of Multivariate Commonality Analysis | p. 236 |
First Objective: Total Diversity Goal | p. 237 |
Second Objective: FSA Overweight Goal | p. 239 |
Third Objective: FSA Underweight Goal | p. 243 |
Conclusions of Scenario Analysis | p. 243 |
Considering Operational Reviews in the Hedge Fund Portfolio Rebalancing Process | p. 245 |
Operational Drag | p. 245 |
Meta Risks | p. 249 |
Operational Factor | p. 250 |
Operational Scenario Analysis | p. 253 |
Can Operational Risk Be Entirely Eliminated? | p. 254 |
Factoring Operational Risk into Total Risk Calculations | p. 256 |
Beyond Scorecard Approaches: Discounting Expected Return | p. 257 |
Discounted Expected Returns with the Operational Factor | p. 261 |
Operational Haircuts | p. 262 |
Expected Return and Operational Risk | p. 263 |
Shape of the Expected Return versus Operational Risk Curve | p. 264 |
Second Operational Threshold | p. 265 |
Final Thoughts | p. 267 |
Looking Ahead: Trends in the Space | p. 269 |
Increased Use of Consultants | p. 269 |
Commoditization of Background Investigations and Canned Operational Due Diligence Reports | p. 272 |
Increased Reliance on Service Provider Consulting Services | p. 277 |
Capture of Hedge Funds by Service Providers and Employees | p. 278 |
Hedge Fund Pursuit of Audit Certifications | p. 280 |
Operational Activism | p. 281 |
AU 332 and FAS 157 | p. 283 |
Development of Hedges to Operational Risks | p. 286 |
Links between Operational Risk and Credit Analysis | p. 288 |
Proposed Reregulation of the Hedge Fund Industry | p. 289 |
Index | p. 293 |
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