Fee benchmarking with every peer fee cited to its own fee table, read twice and signed
Every peer fee your board sees, cited to the peer’s own fee table and signed.
See one case, screen by screen ↓Fee benchmarking is comparing a fund's fees with those of funds that do the same thing, its peer group, to see where its expense ratio ranks, how far it sits from the peer median and why. Fee Benchmarking does this with eight agents: they build the peer group from each fund's holdings and strategy text, read every peer's own prospectus fee table or PRIIPs KID, make the figures like-for-like and rank them on a cited ladder. A product manager decides the peer group, and a Pricing Committee member approves the answer as a signed, dated fee position.
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Every fund launch, fee change and advisory-contract renewal turns on one question: where does our fee sit against funds that do the same thing? Today the answer arrives once a year in a vendor's 15(c) peer report, or an analyst rebuilds the fund fee analysis by hand. Screen a fund-analytics terminal by category label, open each peer's 497K summary prospectus or statutory prospectus, copy the Item 3 fee table into a spreadsheet, then do the same for European peers whose PRIIPs KIDs are in German, French or Italian.
The risk is in the rows nobody re-checks. A quasi-index fund labeled active drags the expense ratio benchmark down. A peer's net fee hides a waiver that ends before the next board meeting. A KID's ongoing costs, which include transaction costs, sit beside a US expense ratio, which does not. And when a director asks where 0.85% came from, nobody can show the page, though the board's 15(c) materials must be kept for six years.
Estimated split for one peer-fee answer on a 14-peer group, by hand and with the solution.
Eight agents build the peer group, read every fee table and KID, and challenge each other; the Pricing Committee signs.
On Friday, October 16, the Watch agent read a 497 supplement: Corvane Global Small Cap Active ETF cut its fee from 0.89% to 0.82%. That puts the July fee position for Quillfield Global Small Cap Active ETF (QGSC, $1.42 billion, a 0.79% unitary fee) out of date, and the Pricing Committee meets on Thursday. Here is what happens next, screen by screen, in the working solution.
Tomás's Today page opens on four items that need him. First: “Answer Nadia: where does QGSC sit now?”, due Thursday at 8:00 a.m. for the Pricing Committee. Beside it, what the agents found since Friday: 37 peer changes read, Corvane's cut, two peer waivers that end April 30, 2027, a new launch the data vendor has not classified yet, and 312 new filings and KIDs read overnight, 4 of them needing a better copy.
“Corvane Global Small Cap Active ETF cut its fee from 0.89% to 0.82%. It touches QGSC and two other positions.”
He types “Where does Quillfield Global Small Cap Active ETF at 0.79% sit against active small-cap ETF peers?” The Planner reads it as the net total expense ratio after waivers, against active global small-cap ETFs and institutional-equivalent classes, as of today. Each step runs in view with its time: the Peer builder screens 12,412 share classes in 48.6 s and keeps 14 of 61 candidates, each with a reason, and the Fee reader reads 41 documents in 1 min 41 s.
Planner: “I read this as net total expense ratio after waivers for Quillfield Global Small Cap Active ETF against active global-small-cap ETFs and comparable share classes, as of Oct 19, 2026, 9:12 a.m. ET.”
The answer arrives as one sentence and a ladder: 15 funds ordered by net fee, the median as a line, gross beside net, waiver end dates and a source chip on every rung, such as “497K · Feb 27 · p. 1”. As first built, QGSC is 6th lowest of 15, 5 bps below a peer median of 0.84%. Thirteen of 14 figures are confirmed on a second reading, and three changes to the peer group wait for Tomás in the agents' panel.
Normalizer: “KID transaction costs removed · share classes mapped · 2 waivers end April 30, 2027.”
Valoris Global Small Cap Equity UCITS ETF files its KID in German. The source opens with the original table beside the English reading: Laufende Kosten 0,92 %, of which Transaktionskosten 0,07 %. A US fee table leaves portfolio transaction costs out, so the like-for-like figure is 0.85%. Two readings on different models agree, at 0.98 and 0.97 confidence. One French figure, Aubrac's KID page 2 read at 0.82 from a scan, falls below the 0.90 threshold and goes to Tomás, who confirms it against the scan.
Rule L2: KIDs count management fees and other administrative or operating costs only; transaction costs and performance fees are excluded.
On a different model, the Peer challenger proposes three changes. Drop Pemberly Global Small Cap Factor ETF at 0.39%: labeled active, but its active share is 18% across 2,940 holdings (confidence 0.94). Add Kestrin Global Small Cap Active ETF, launched September 28, 2026, at 0.95% (0.88). Remove Stellwater Global Small Cap Discovery ETF, 64% in US companies (0.71). Tomás accepts the first two and rejects the third with a reason code, and the median settles at 0.85%.
Reason code: “Peer kept: mandate global, US weight within peer range (48–66%).”
Ormsby Lane at 0.80% and Fairhollow at 0.85% are both 0.95% gross, and their waivers end April 30, 2027, before the board's next annual review. One click on “After Apr 30, 2027” re-ranks the ladder: the median rises to 0.87% and QGSC sits 8 bps below it, still 5th lowest.
Ormsby Lane's fee table, note 1: the waiver runs “until at least April 30, 2027. The agreement may be terminated before that date only by the Fund’s Board of Trustees.”
The send summary checks itself: 14 peers, every rung cited, 41 documents; two challenger changes accepted and one rejected, each with a reason; 14 of 14 figures confirmed, 1 by Tomás. It goes to Nadia Okonkwo, due Thursday, October 22 at 8:00 a.m., before the Pricing Committee. When he tries to approve it from Sign-offs a minute later, the attempt is blocked and written to the audit trail.
“You prepared this answer, so you cannot approve it (rule S1).”
Nadia opens the sign-off: 0.79% against a peer median of 0.85% (14 peers), replacing FP-2026-0318 from July. She picks the reason code “Hold the fee: within 10 bps of peer median” and confirms. The answer becomes fee position FP-2026-0412, dated October 19, 2026, with her name on it.
“I, Nadia Okonkwo, confirm this decision. It is recorded with my name, the time, the reason and the evidence.”
The position holds its sentence and the decision: hold the fee at 0.79%, and review it if the waivers are not renewed. The ladder is frozen as approved. Version 1 of July 14 read a 0.86% median; version 2 records Corvane's cut, Kestrin added, Pemberly removed and Harrowden liquidated. In the restricted scenarios, each basis point is $142,000 a year at $1.42 billion, so a cut to 0.75% would cost $568,000 a year and move QGSC to 4th lowest.
Fee scenarios are visible only to the Pricing Committee, the fund's product manager and the Fund Treasurer.
Kenji, the Board Reporting Analyst, inserts FP-2026-0412 into section 4.12 of the Quillfield ETF Trust 15(c) book, the expense group for QGSC, for the December 9, 2026 board. Materials go to independent counsel by November 18. The Pack writer drafts the paragraph from the approved position, each figure linked to its page, and Grace Whitfield, the Fund Treasurer, signs the section.
“The Fund’s net total expense ratio of 0.79% ranks 5th lowest of 15 funds in its expense group … and is 6 basis points below the group median of 0.85%.”
The same fee question, seen by five of the people who carry it: what their week looked like, and what it looks like now.
Eight agents build the peer group, read every fee table and KID, and challenge each other; the Pricing Committee signs.
Turns a plain question into a scope: the measure (net after waivers unless told otherwise), strategy, vehicles, share-class basis and as-of date. It shows the plan before the work starts.
Screens 12,412 share classes and builds the peer group from each candidate's principal investment strategy text and latest holdings file: median market cap, US weight, holdings and active share.
Argues with the peer group on a different model: looks for quasi-index funds, missing launches, strategy drift and share-class mismatches, and proposes each change with a reason, citations and a confidence.
Reads every fee-table line, from N-1A Item 3 tables, 497K summary prospectuses, 497 supplements and PRIIPs KID cost tables, in its original language, with the English beside it.
Makes the figures like-for-like from written rules: net against gross, waivers and their end dates, KID transaction costs removed, share classes mapped, acquired fund fees excluded for ETFs.
Re-reads every cited figure blind, on a different model, and compares it with the first reading.
Reads every new 497, 485(b) and KID, finds fee cuts and rises, waiver ends, launches and closures, re-runs the fee positions each one touches and tells the owner.
Drafts 15(c) expense-group paragraphs and launch-memo pricing sections from approved fee positions, with every figure linked to its source.
Approve positions, sign book sections. The agents propose; a named person decides.
Ask about any rung, waiver or scenario, or tell the agents what to do. They answer with the page behind every figure and act on the ladder.
If both waivers lapse?
If Ormsby Lane and Fairhollow do not renew, both move to 0.95% on May 1, 2027. The median rises to 0.87% and QGSC sits 8 bps below it, still 5th lowest. I switched the ladder to “After Apr 30, 2027”.
Why Valoris 0.85%?
Valoris's German KID, page 2, lists Verwaltungsgebühren und sonstige Verwaltungs- oder Betriebskosten 0,85 % and Transaktionskosten 0,07 %, together Laufende Kosten 0,92 %. A US fee table leaves portfolio transaction costs out, so the like-for-like figure is 0.85% (rule L2). I opened the page.
Cost of a cut to 0.75%?
Restricted. At today's assets of $1.42B, each basis point on QGSC is $142,000 a year. A cut to 0.75% is 4 bps: $568,000 a year. It would move QGSC to 4th lowest, 10 bps below the median. This scenario is visible only to the Pricing Committee, the fund's product manager and the Fund Treasurer.
Draft the board sentence
Draft for the 15(c) book, used only once the position is approved: “The Fund's net total expense ratio of 0.79% ranks 5th lowest of 15 funds in its expense group of active global small-cap ETFs and comparable share classes, and is 6 basis points below the group median of 0.85%. Two peers' contractual waivers end April 30, 2027; without them the median would be 0.87%.”
13 screens from the working solution, on its sample data. Pick one to see it large.
What counts as a peer and how figures are made comparable are written rules. Only the administrator edits them, and a rule or threshold change takes effect once the Pricing Committee approves it.
| Setting | Default | Choose from |
|---|---|---|
| Measure (L1) | Total annual fund operating expenses after fee waivers (N-1A Item 3) | On or off |
| KID costs (L2) | Management fees and other administrative or operating costs only | On or off |
| Share classes (L4, L5) | Mutual funds: no sales load, no 12b-1 fee · UCITS: institutional accumulating, base currency | Each rule on or off |
| Waiver flag (L6) | Ends within 12 months of the next board date | On or off |
| Active (R1) | Active share of at least 60% | Any percentage |
| Small cap and global (R2, R3) | Median market cap under $5B · US weight 35–70% | Any cap and range |
| Minimum assets (R4) | $100M | Any amount |
| Checker confidence threshold | 0.90 | Changed only with Pricing Committee approval, backed by evaluation results |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample fund data · “target” = the design goal, measured in the live solution · “estimated” = our estimate (where the working days go, and $1 million a year per basis point on a $10 billion fund) · “typical” = published figures (ICI, 2026 Investment Company Fact Book, chapter 6: asset-weighted average expense ratio of equity mutual funds 0.40% in 2025 against 0.99% in 2000; 82% of equity mutual fund assets in the lowest-cost quartile). Context: Investment Company Act of 1940, Section 15(c), and Rule 31a-2(a)(6) on keeping 15(c) materials six years; Form N-1A, Item 3; PRIIPs Delegated Regulation (EU) 2017/653. People, funds, firms and figures named on this page, including Quillfield Capital and every peer fund, are fictional: characters and sample data in the working solution.
Fee benchmarking is comparing a fund's fees with those of funds that do the same thing, its peer group, to see where its expense ratio ranks, how far it sits from the peer median and why. Fee Benchmarking does this with eight agents: they build the peer group from each fund's holdings and strategy text, read every peer's own prospectus fee table or PRIIPs KID, make the figures like-for-like and rank them on a cited ladder. A product manager decides the peer group, and a Pricing Committee member approves the answer as a signed, dated fee position.
The Peer builder reads each candidate's principal investment strategy text and latest N-PORT holdings, measures median market cap, US weight, holdings and active share, and applies your peer rules, keeping a fund only with a cited reason. The same written rules make an ETF expense ratio comparison and a mutual fund fee comparison like-for-like: a mutual fund is compared on its class with no sales load and no 12b-1 fee, a UCITS fund on its institutional accumulating class. A Peer challenger on a different model then proposes changes, such as dropping a quasi-index fund with 18% active share, and the product manager accepts or rejects each one with a reason code.
Net, unless you ask otherwise: the Planner reads a question as the net total expense ratio after fee waivers. The gross figure is total annual fund operating expenses before any fee waiver or expense reimbursement; the net figure is after it, as shown in the N-1A Item 3 fee table. Each rung shows both, with the date the waiver ends, and one click shows the ladder as it will look once waivers lapse. In the sample, two peers at 0.80% and 0.85% net are 0.95% gross from May 1, 2027, which moves the median from 0.85% to 0.87%.
Not as printed. PRIIPs KID costs count portfolio transaction costs in the ongoing costs, and a US expense ratio leaves them out. The Normalizer takes the transaction costs out under a written rule and shows the original-language line beside the English, so a German KID's Laufende Kosten 0,92 % becomes a like-for-like 0.85%.
Under Section 15(c) of the Investment Company Act of 1940, directors request and evaluate the information reasonably necessary to evaluate the advisory contract, and comparative fees are one of the Gartenberg factors courts weigh. Approved fee positions flow into the 15(c) book, where the Pack writer drafts each expense-group paragraph with every figure cited and the Fund Treasurer signs the section. Positions, sources and decisions are kept 7 years.
The Watch agent reads every new 497, 485(b) and KID, overnight 312 of them in the sample, and finds fee cuts, waiver ends, launches and closures. It re-checks the fee positions each change touches and drafts a new version for the owner to approve. It never edits an approved position.
Yes. The agents propose and cite; they never approve, send to a board or change an approved position. The product manager decides every peer change with a reason code, a Pricing Committee member approves the position, the Fund Treasurer signs the board-book section, and the maker of anything can never approve it.
The Agentic Solution Engine builds and deploys it from your requirements and documents: your product master, last year's 15(c) peer groups, your like-for-like and peer rules and your filings and KID feeds. It goes live once every quality gate has passed. We will walk you through it on one of your own funds first.
Every 15(c) answer cited and checked against last year, ready 10 days before the deadline.
1-min demoFund Launch ManagementFirst NAV on the planned date: every slip caught early, re-planned and signed off.
1-min demoFund RationalizationEvery subscale fund, each quarter: a cited case argued both ways, signed before the board.
1-min demoWe'll run Fee Benchmarking on one of your own funds against its peers' public filings.