SystemInvestment Compliance & Surveillance

Investment Guideline Monitoring

Investment guideline monitoring where you work every overnight alert with the agents: recomputed, cited, and approved by a person in one click

Of 412 overnight alerts, 9 reach a person, and every close cites its clause and approver.

See one case, screen by screen ↓
demo9of 412overnight alerts that needed a person on the sample Monday; the other 403 arrived as cited proposals in 7 reason groups
demo$59,050make-wholefor the day's real breach, with the smallest cure tested against all 31 rules of the mandate
targetSamedaybreaches confirmed the day they are found, not days later after re-performance by hand
target100%of closes carrying their clause, their evidence and a named approver
In short

What is Investment Guideline Monitoring?

Investment guideline monitoring, also called investment compliance monitoring or post-trade compliance monitoring, is the daily work of testing every mandate and fund against the limits in its investment management agreement, prospectus or side letter, then investigating each alert, confirming real breaches, curing them and notifying the client. Investment Guideline Monitoring puts seven agents on that queue: they recompute each alert from the custodian position and the exact clause, check every input against a second source and draft cures and notices, while analysts classify and the Head of Investment Compliance approves.

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Updated

The problem

Why investment guideline monitoring still eats the compliance morning

Investment guideline monitoring starts every night, when the compliance engine re-runs its post-trade compliance checks on every mandate and fund against its coded rules and hands the investment compliance team an alert queue. Most alerts are not breaches: a stale price, one agency's downgrade that the client agreement does not count, a sector code a vendor changed overnight, a corporate action not yet booked, a soft warning inside the band. Analysts still open each one, re-perform the test by hand against the custodian file and the agreement PDF, and a second reviewer re-performs every potential active breach again.

Real breaches are confirmed late, cures are planned on spreadsheets, and client letters are written from scratch while the notice clock in the IMA runs. The rule that fired is often coded differently from the agreement it came from, so the same false alert comes back tomorrow. France's AMF inspected five managers and found that breaches are detected automatically but “the investigation of these breaches remains a manual activity”, and the SEC's 2026 examination priorities say examiners are looking for evidence that policies are not only written but effectively enforced and tested in practice.

typical$1.6Mlossesin a March 2025 SEC case against an adviser whose registered fund broke its 25% single-industry concentration limit for more than two years
typical800a yearguideline breaches at the busiest of five managers the AMF inspected, where investigating them remained a manual activity
typical4×as many passive breaches as active ones in the same AMF inspection, each needing its own cure clock and record
Where the compliance team's day goes after an overnight run, in hoursestimated
By hand9 days
With the solution1.6 days
  • Pulling the overnight post-trade alerts and pre-trade overrides, and sorting repeats1 → 0.1 d
  • Re-performing each test against the custodian file and the agreement3 → 0.5 d
  • Checking prices, ratings and sector codes against a second source1.5 → 0.2 d
  • Second-reviewer re-performance of potential breaches1.5 → 0.3 d
  • Planning cures and drafting client and board notices2 → 0.5 d

Estimated split for one analyst on an ordinary day, by hand and with the solution.

How it works

How an overnight alert is closed

Seven agents recompute, re-source, cure and draft every alert; the analyst classifies and the Head of Investment Compliance approves.

What comes in
Alerts and data in412 alerts, 618 mandates · engine, order system, custodian, vendors, agreements in their own language
Agents at work
Intake agentrepeats linked, grouped
Then
Triage agentposition + exact clause
Data Check agentsecond source
Agreement agentclause, own language
Then
Cure Plannersmallest safe sale
Notice agentcited client letter
Then
SLA Watch agentclocks and escalations
A person decides
Analyst and Head of Investment Complianceanalyst classifies, head approves, PM confirms the cure
What comes out
Every alert closed with a cited reason
Breaches cured and verified
Client notices on time
One case, step by step

One overnight alert queue, from 412 alerts to cured and notified

Quillfield Capital monitors 618 mandates and funds, $705.4B, against 14,820 coded rules. On Monday, October 19, 2026, the overnight run, on positions as of Friday's close, raised 412 alerts: 389 post-trade and 23 pre-trade overrides. Here is what happens next, screen by screen, in the working solution.

  1. 0108:12 ET

    Nine alerts need a person, and the agents say where to start

    Dana Okafor · Head of Investment Compliance

    Dana's home shows three numbers: 9 need a person, 403 proposed closes in 7 reason groups, 5 open breaches. Beside the nine is how the agents spent the night, 06:02 to 07:38 ET: the Intake agent linked 97 repeats, the Triage agent recomputed 315 alerts from custodian positions and their clauses, and the Data Check agent re-sourced 141 prices, ratings, sectors and corporate actions. A banner notes classification vendor B arrived 22 minutes late; 29 sector checks were re-run and no result changed.

    “5 items wait for your approval before 12:00 ET. Start with Calder Basin Pension: the agents say the Velmora Telecom downgrade is not a breach under section 4.2.”

  2. 02The limit wall

    Every key limit of a mandate, against its limit line

    Dana Okafor · Head of Investment Compliance

    Calder Basin Pension is a $4.82B Core Plus Fixed Income mandate with 27 coded rules, run by PM Janet Morrow. The wall shows its 12 key limits as thermometers, recomputed from the custodian file at 06:21 ET: single issuer 2.40% of 3.0%, securitized 29.50% of 35.0%, cash 2.30% against a 1.0% minimum. One tube carries a red cap: the credit floor BBB−, at 0.96% against a 0.0% maximum. The rail beside it shows the day's fold: 412 raw alerts, minus 97 repeats, 141 bad or late inputs, 118 soft warnings and 47 the agreement rules out, leaves 9.

    “Showing 12 key limits of 27. The other 15 are below 60% of their limits.”

  3. 03Open the conversation

    The alert recomputed from the position and the exact clause

    Triage, Agreement and Data Check agents

    Agency C cut Velmora Telecom 4.875% 2033 to BB+ on Friday at 17:42 ET, and the engine's floor rule fired. In the conversation, the Triage agent recomputes from the custodian file: $46.3M par, 0.96% of the mandate, and notes the engine codes the floor on the lowest of three ratings. The Agreement agent reads IMA Schedule B section 4.2: the applicable rating is the second-highest of the three. The Data Check agent confirms the ratings from a second vendor: Agency A BBB−, Agency B Baa3, Agency C BB+. The proposal is not a breach, with 97% confidence.

    IMA Schedule B §4.2, p. 14: “the applicable rating shall be the second-highest of the three ratings”

  4. 04One click

    Approved, with the reason code and the clause on record

    Dana Okafor · Head of Investment Compliance

    Tomás Reyes classified the alert at 07:52 with the reason code “Clause read: rating method”. Dana reads the thread, checks the ratings table and approves the close. The decision records her name, the time, the reason and the evidence, and the nine becomes eight. The Triage agent has also drafted a rule fix: 23 mandates code this floor on the lowest rating while their agreements use the middle one.

    “Closed AL-104127 — not a breach · clause cited · approved by Dana Okafor”

  5. 05Agents disagree

    When the agents read it differently, nothing closes

    Tomás Reyes · Compliance Analyst

    Harlow County Employees' Retirement Fund must hold at least 1.0% cash. The Triage agent reads the guidelines as measuring cash as reported by the custodian: $3.40M, 0.62%, below the minimum. The Data Check agent disagrees: section 3.5 values unsettled FX on trade date in the manager's accounting, and with a $3.78M EUR/USD spot sale settling that day, cash is 1.31%. No close is proposed. The alert goes to Tomás to classify, and a different person approves.

    “We read the agreement differently, so I have not proposed a close. Escalated to a person.”

  6. 06Proposed closes

    403 proposed closes, spot-checked by reason group

    Mei Lin Goh and Tomás Reyes · Compliance Analysts

    The rest of the queue waits in seven reason groups, each alert cited: 97 repeats of an open alert, 38 stale or wrong prices, 52 rating feed mismatches where the clause method still passes, 29 sector code changes, 22 corporate actions not yet booked, 118 soft warnings inside the warning band and 47 the agreement says are not a breach. An analyst opens five alerts in a group before confirming it, and can exclude any one; a different person approves the group.

    Spot-check rule: open 5 alerts before confirming a group. No one approves their own classification.

  7. 07The real breach

    A finance subsidiary the pre-trade check missed

    Tomás Reyes · Compliance Analyst

    Ostrander State Teachers' Retirement System is a $1.17B Global Credit mandate run by Marcus Hale. Order ORD-77812 on Oct 16 bought $9.0M par of Harrow Peak Energy Finance 7.25% 2031. The security master had no link to the guarantor parent, so the pre-trade check passed. Aggregated as IMA section 5.1(b) requires, $54.0M of parent bonds and $9.4M of the 2031s make $63.4M, 5.42% against a 5.00% cap. Tomás classified it an active breach at 07:58, and the breach register opened BR-2026-0042 with the client notice due Oct 21.

  8. 08Before the PM trades

    The smallest cure, tested against every rule of the mandate

    Cure Planner

    The Cure Planner tests three options against all 31 rules, keeping a 0.15% buffer. Option A sells $6.7M par of the 2031s, bought at 101.25 and bid at 100.40, taking the issuer to 4.85% and tripping no other rule, for an estimated make-whole under IMA section 9.4 of $59,050. Option B sells the 2029s at a larger cost, $71,400; option C trips the minimum lot rule. The plan goes to Marcus Hale, who confirms the trade, and the order goes to the order management system as ORD-77955.

    The Cure Planner never sends an order: the PM confirms the trade, and the cure is verified by a re-test.

  9. 09Notice due Oct 21

    The client letter, drafted from the breach record and cited

    Sofia Brandt · Client Service Director

    The Notice agent drafts the letter to Harold Pruitt, Deputy Chief Investment Officer, under IMA section 9.3: written notice within two business days. It sets out what happened, why the pre-trade check did not aggregate the two issuers, the corrective sale and the restoration under section 9.4, each statement cited to the record. Dana approves it; Sofia sends it through the CRM.

    “Aggregated as section 5.1(b) requires, the issuer represented 5.42% of the Account's market value, above the 5.00% limit.”

  10. 10In the client's language

    A Japanese agreement, read beside its English reading

    Agreement agent

    Kitami Prefectural Mutual Aid Association's guidelines are in Japanese. Its IT sector reached 35.8% against 35%, after the sector rose 4.1% with no IT purchases, so the breach is passive. The Agreement agent shows page 6 of the original beside its English reading, sentence by sentence: Article 7(2) requires a prompt report and correction within 10 business days. The notice is drafted in 日本語 and English, with the cure due Nov 2.

    Article 7(2): “the Manager shall promptly report to the Client and correct it within 10 business days.”

Who it’s for

Built for everyone who touches a guideline alert.

The same overnight queue, seen by five of the people who work it — what their morning looked like, and what it looks like now.

DO
Dana OkaforHead of Investment Compliance · approves every close, classification and notice
Head of Investment Compliance
Before
Owns an overnight queue of hundreds of alerts and signs off on closes she cannot see the evidence for without re-performing them.
Now
Starts with the nine that need her, reads each alert as a cited conversation with the agents, and approves with a reason code in one click.
TR
Tomás ReyesCompliance Analyst, New York · classifies alerts and confirms groups
Compliance Analyst
Before
Spends half the morning proving, again, that a single-agency downgrade does not count under section 4.2.
Now
Gets each alert recomputed from the position and the clause, with a second source; classifies where the agents disagree, and never approves his own work.
MH
Marcus HalePortfolio Manager, Global Credit, London · confirms cure trades
Portfolio Manager, Global Credit
Before
Gets breach emails mid-trade and has to work out what to sell without tripping another limit.
Now
Receives the smallest sale, tested against every rule of the mandate, and confirms it; he cannot close alerts on portfolios he manages.
SB
Sofia BrandtClient Service Director, Institutional · sends approved notices
Client Service Director
Before
Writes each breach letter to a pension fund from scratch and answers the consultant's follow-up from email threads.
Now
Sends a letter drafted from the breach record, every statement cited and approved by the Head of Investment Compliance first.
VL
Victor LamChief Compliance Officer · approves threshold, rule and agent changes
Chief Compliance Officer
Before
Reports to the board from a breach log rebuilt each month by hand.
Now
Reads dispositions by 12:00 ET, breaches cured inside their period and the noisy rules with fixes proposed, and the board report the agents draft from the register and the audit trail.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents recompute, re-source, cure and draft every alert; the analyst classifies and the Head of Investment Compliance approves.

Intake agent

Pulls the overnight post-trade alerts from the compliance engine and the pre-trade overrides from the order management system, links repeats to their open twin and groups the rest by root cause.

  • Never drops an alert; repeats stay linked
  • Never closes anything
Triage agent

Recomputes each alert from the custodian position and the exact clause, and proposes a tag and a classification with citations.

  • Proposes only; a person approves
  • Below 90% confidence it hands to a person
  • Disagreement with Data Check escalates
Data Check agent

Re-sources each price, rating, sector and revenue figure from a second source — two pricing, rating and classification vendors, issuer filings and the security master — and flags disagreement.

  • Never picks a winner when sources disagree
  • Escalates instead
Agreement agent

Finds the governing clause in the IMA, prospectus or side letter, reads it in its own language and gives the English reading side by side, page-cited.

  • Never paraphrases without the page-cited original
Cure Planner

Proposes the smallest sale list that cures a breach without tripping another rule of the mandate, and estimates the make-whole.

  • Never sends an order
  • The PM confirms the trade
Notice agent

Drafts client, board and depositary notices from the breach record, every sentence cited, in the client's language.

  • Never sends
  • The Head approves; the Client Service Director sends
SLA Watch agent

Runs the clocks — disposition by 12:00 ET, PM action within 1 business day, weekly passive follow-up, notice deadlines — and escalates to named people.

  • Never changes a deadline
Head of Investment Compliance

Approves every close. The agents propose; a named person decides.

Ask in plain words

Ask the agents about any guideline breach alert, mandate or rule

Ask on the home page, on the limit wall or inside an alert. The agents answer with the clause and the data behind it, and take you to the screen.

Why is the Velmora Telecom alert not a breach?

Calder Basin Pension holds $46.3M par of Velmora Telecom 4.875% 2033 (0.96%). Agency C cut it to BB+; Agencies A and B still rate it BBB− and Baa3, confirmed by two vendors. Schedule B section 4.2 uses the second-highest of three ratings — BBB−, at the floor. Not a breach. Tomás Reyes classified it; it is waiting for your approval.

Which mandates hold Harrow Peak Energy, and how close to their caps?

Four mandates hold Harrow Peak Energy (parent-aggregated). Only Ostrander State Teachers' Retirement System is over: 5.42% vs 5.00%. Quillfield Global High Yield Fund 1.9% of 3%; Pennant Teachers' Pension Fund 2.6% of 5%; Kestwick Mutual Insurance 1.1% of 2%. The security master lacks the guarantor link; a fix is proposed in Reports.

Draft the Kitami report in Japanese and English

The guidelines (Japanese original) require a prompt report and correction within 10 business days. The draft states the cause — the IT sector rose 4.1% with no purchases by us — and the cure by Nov 2. It is ready in 日本語 and English for your approval.

Which rules made the most false alerts this month?

Top three by false alerts in October: credit floor coded on the lowest rating — 61 alerts in 23 mandates; sector remaps from classification vendor A — 41; cash measured before FX settlement — 22. Each has a drafted rule fix for the rule-coding team and the CCO.

Every screen

The working solution, as it ships.

13 screens from the working solution, on its sample data. Pick one to see it large.

Today: what needs a personThe investment compliance home: 9 of 412 overnight guideline alerts need a person, 403 proposed closes, open breaches, how the agents spent the night and the box to ask them.
The limit wallEvery key investment guideline limit of a mandate as a thermometer against its limit line, the overnight alert as a red cap, and the day's 412 alerts folding to 9.
The alert as a conversation with the agentsA post-trade compliance alert recomputed from the custodian position, the IMA clause quoted, both rating vendors side by side and a proposal with its confidence.
Approved in one clickThe close approved by the Head of Investment Compliance with a reason code, the clause cited and the maker named.
When the agents disagreeCustodian cash and accounting cash read differently: no close proposed, both readings shown and the guideline breach alert escalated to an analyst.
Proposed closes by reason group403 proposed closes in seven reason groups, with a five-alert spot check before an analyst confirms a group and a different person approves.
The breach registerActive and passive breaches in one breach register, with deadlines, cure status, notices and compensation, and the clocks for each type.
The cure planThree cure options tested against all 31 rules of the mandate, the smallest recommended, the make-whole estimate and the step to send it to the PM.
The client noticeA guideline breach notice drafted from the breach record under the IMA notice clause, every statement cited, with its routing from draft to approval to sending.
The agreement in its own languageInvestment guidelines in Japanese beside the English reading, sentence by sentence, with the page cited and the alerts that cite it.
Reports and noisy rulesDispositions by 12:00 ET, breaches confirmed the same day, cures and notices on time, the rules that cause most false alerts with a fix proposed, and the board report draft.
The examiner exportThe audit trail of every person and agent action, exported with dispositions, evidence files, agent versions and approvals, sealed with a SHA-256 manifest.
Thresholds and timersConfidence threshold, warning band, disposition and breach-confirmation times, escalation and cure timers; every change goes to the CCO for approval.
Governance

Investment guideline monitoring built for the examiner: cited, maker-checked, on the record.

Maker-checker on every closeThe analyst classifies; the Head of Investment Compliance approves every close, breach classification and notice. No one approves their own classification, a PM cannot classify or close alerts on portfolios they manage, and administrators cannot approve alerts — locked by policy.
Two agents check each otherThe Triage agent recomputes from the custodian position and the clause; the Data Check agent re-sources every input from a second vendor. When they disagree, the alert escalates to a person with both readings side by side, and no close is proposed.
Every value cited to its clause or recordEach agent statement links to the clause page, the custodian file or the vendor record. Documents in Japanese or Bahasa Indonesia, such as a Japanese client's guidelines or an issuer's annual report, are shown in the original beside the English reading.
Always a person on the rules that matterCredit-quality floors, derivatives limits, ESG exclusions, UCITS investment restrictions such as 5/10/40 and other fund-law limits, any rule with a client notice clause, every pre-trade override and anything below the confidence threshold always go to a person. In adopting Rule 38a-1, the SEC listed violations of investment restrictions among the areas a fund's Rule 38a-1 compliance program should cover.
Agents propose; people trade and sendThe agents read every system through read-only service accounts and never write to the engine, the order system or the custodian. Orders are created only when a PM confirms; notices go only when the Client Service Director sends them.
An audit trail the examiner can testEvery action by a person or an agent is logged with who, what, when, why and which evidence, kept 7 years. The examiner export for today, October or the year to date is sealed with a SHA-256 manifest, and every agent version change needs the CCO's approval.
Configuration

Your investment guideline compliance thresholds, timers and controls

The controls the agents work inside. The Compliance Systems Administrator edits them; saving creates a change request, and nothing changes until the CCO approves.

SettingDefaultChoose from
Propose a close at confidence of at least90%Below it, the alert goes to a person
Warning band starts at90% of limitValues in the band are logged as soft warnings, not breaches
Disposition due by12:00 ET same dayBreach confirmation by 17:00 ET same day
Active breach: PM action within1 business day, then CIOThe SLA Watch agent escalates to named people
Passive breach: follow-up every7 daysCure within 15 business days unless the agreement says otherwise
Client notice, if the agreement is silent2 business daysThe agreement's own notice clause wins
Spot-check before confirming a group5 alertsPer reason group, before an analyst confirms
Data residency and retentionUS East · EU West · Singapore; 7 yearsRetention beyond the 5 years of SEC Rule 204-2
Connections

Works with the systems your compliance data already lives in

Compliance engine and order management systempost-trade batch, rule definitions, pre-trade overrides and cure orders
Custodian and portfolio accountingdaily holdings and cash, trade-date positions, FX and futures
Fund administratorNAV, capital activity and impact calculations
Pricing, rating and classification vendorstwo independent sources each for prices, agency ratings, sectors and revenue mix
Security masterissuer hierarchy, guarantor links and identifiers
Document management, CRM, email and chatIMAs, prospectuses and side letters; client contacts and notice delivery; escalations
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
9of 412
overnight alerts that still need a person; 403 arrive as cited, grouped proposals
9 of 412
illustrative day, 618 mandates
target
Sameday
breach confirmed the day it is found, instead of T+2 to T+5 after manual re-performance
TodayT+2 to T+5
With agentssame day
target
100%
of closes carry their clause, evidence and a named approver; the SEC tests policies enforced in practice
every close
maker-checker

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (SEC press release 2025-55, March 17, 2025 — a registered fund's 25% single-industry concentration limit broken from November 2021 to June 2024, about $1.6 million of losses; AMF thematic inspections of five managers' monitoring of fund investment ratios, February 19, 2025 — 20 to 800 breaches a year, passive breaches four times as frequent as active ones). Also cited: SEC 2026 examination priorities (Dorsey, December 2025); CSSF Circular 24/856 and its FAQ of December 24, 2024; SEC Rule 38a-1 adopting release IC-26299. People, firms, mandates and securities named on this page are fictional — characters and sample data in the working solution.

Questions

What investment compliance teams ask about investment guideline monitoring.

What is investment guideline monitoring?

Investment guideline monitoring, also called investment compliance monitoring or post-trade compliance monitoring, is the daily work of testing every mandate and fund against the limits in its investment management agreement, prospectus or side letter, then investigating each alert, confirming real breaches, curing them and notifying the client. Investment Guideline Monitoring puts seven agents on that queue: they recompute each alert from the custodian position and the exact clause, check every input against a second source and draft cures and notices, while analysts classify and the Head of Investment Compliance approves.

What is the difference between an active breach and a passive breach?

An active breach is caused by the manager, such as a purchase; in the working solution it is cured as soon as possible, the PM must act within one business day before escalation to the CIO, and the client is restored for any loss. A passive breach comes from market movement or redemptions; it gets weekly follow-up and a cure within 15 business days unless the agreement says otherwise. The analyst classifies each one with a reason code and the Head of Investment Compliance approves. For a UCITS fund under CSSF Circular 24/856, in force since January 1, 2025, active breaches are notified to the CSSF and remedied without delay, while a passive breach is not notified but corrected within a reasonable period in investors' interest; the agents draft the passive justification and the depositary notice for a person to approve.

Why are most post-trade compliance alerts not real breaches?

On the sample day, 97 of 412 alerts repeated an open alert, 141 came from bad or late inputs such as stale prices, rating feed mismatches, sector remaps and unbooked corporate actions, 118 were soft warnings inside the warning band and 47 were ruled out by the agreement itself. The agents prove each case with a citation and group them by reason, so an analyst confirms a group after spot-checking five and a different person approves.

How is a guideline breach cured and reported to the client?

The Cure Planner tests cure options against every rule of the mandate and recommends the smallest sale that trips nothing else, with a make-whole estimate. The PM confirms the trade, and the cure is verified by a re-test. The Notice agent drafts the client, board or depositary notice from the breach record under the agreement's notice clause; the Head of Investment Compliance approves it and the Client Service Director sends it.

Can it read investment guidelines written in other languages?

Yes. The Agreement agent reads IMAs, prospectuses and side letters in their original language and shows the passage beside its English reading, page-cited. In the working solution it reads a Japanese pension client's guidelines and a Bahasa Indonesia annual report, and drafts the Japanese client's notice in 日本語 and English.

Does it replace our compliance engine or order management system?

No. It works beside your post-trade compliance software: it reads the compliance engine, order management system, custodian, accounting, vendors and document store through read-only service accounts and never writes to them. When a coded rule keeps firing for a reason the agreement rules out, the agents draft a rule fix with the clauses as evidence for your rule-coding team and the CCO.

Do people stay in control of every close and breach?

Yes. Agents never close, trade or send. The analyst classifies, the Head of Investment Compliance approves, the PM confirms the cure trade, the Client Service Director sends the notice and the CCO approves threshold, rule and agent changes. Where the agents disagree, or confidence is below 90%, the alert goes to a person.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents — your agreements, coded rules, escalation policy and the systems behind them — and it goes live once every quality gate has passed. First-time setup connects the systems, imports the mandates and maps each coded rule to its clause, then runs the agents in shadow mode beside your analysts before they go live.

See it on
your mandates.

We'll run Investment Guideline Monitoring on a sample of your own overnight alerts and the agreements behind them.