NAV oversight that checks every administrator NAV against your own books before it publishes
Every NAV checked against your books before it goes out, with breaks held, not published.
See one case, screen by screen ↓NAV oversight is an asset manager's own check of the net asset value its fund administrator strikes, because the liability for a wrong NAV stays with the manager and the fund board. In NAV Oversight, seven agents check each administrator NAV against a shadow NAV built from your own books, explain every break with its cited source, size it under your NAV error policy and draft the challenge; the controller asks them questions in plain words, reads the evidence and holds or releases each NAV before the cut-off.
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Asset managers hand the books of their funds to administrators, but the liability for a wrong net asset value stays with the manager and the fund board. Every evening the administrator's NAV pack — a PDF summary, positions, prices, a trial balance and the capital activity — lands late in the day, and the oversight team has under an hour before the publication cut-off to check hundreds of share classes, usually by NAV reconciliation in spreadsheets and email.
A stale price, a corporate action announced in Portuguese or Japanese, an accrual or an FX rate can put a NAV a cent a share out. Published, that is a NAV error: sized under the fund's own NAV error policy, the fund made whole or shareholder accounts reprocessed, and reported to the board. A full shadow book costs a second accounting team, partial checks miss what nobody looks at, and when the board or an examiner asks for the evidence, it is rebuilt from email.
Estimated split of analyst-days in a month for one cycle of about 340 share classes, checked by hand and with the agents by exception — in line with the 3× target, not a measured result.
Seven agents shadow, explain, size and challenge every NAV; a controller holds or releases.
Friday, October 16, 2026, the Americas cycle at Quillfield Capital: 96 funds and 340 share classes struck by Northgate Fund Services, a 6:00 p.m. ET cut-off, and one bond price that has not moved in five business days. Here is what happens next, screen by screen, in the working solution.
Each share class sits on its own tolerance band: Northgate's NAV at the center, the shadow NAV as a tick, the fund's policy at the edges, sorted so whatever breaks policy is on top. Of 340 classes, 314 are within band or released, 17 explained by the agents, 7 over policy in 2 funds and 2 waiting for a pack. Beside the tape, the agents' thread says what they found: the Intake agent collected Northgate's pack for 95 of 96 funds, and the Michigan Municipal Bond Fund pack is late — Priya Raman sent a reminder at 5:21 p.m.
Next: “Quillfield Short Duration Fund: hold before it publishes.”
The Shadow agent rebuilt all four classes from Quillfield's own books — 412 positions, prices from the primary vendor, FX at 4:00 p.m. ET, accruals of $14.2M and the day's capital activity: class I at 10.129, against Northgate's 10.142. The Driver agent splits the gap: 1.2 cents is price, because Northgate still marks the Corvane Logística 5.25% 2029 notes at 101.80, unchanged for five business days, while the primary vendor fell to 99.40 — 2.40 points on $134.2M par is $3,220,800. The last 0.1 cent is a $268,400 fee true-up the board approved on October 15, which Northgate books on October 19.
Driver agent · 97% confident · every figure links to its source.
Why did the bond fall? Corvane Logística's Fato Relevante of October 13 asked holders of the 2029 notes for a temporary waiver of the leverage ratio, with net debt to EBITDA estimated at 4.6 times against a 4.0 limit. The original Portuguese sits beside the agent's English translation with the figures highlighted, and the provenance below: the document, page 1, paragraphs 1–2, retrieved from the corporate-action feed, and its fingerprint.
“Portuguese · shown beside English”
Before anyone is asked to decide, the Challenger agent re-prices Corvane 2029 without the primary vendor: the secondary vendor at 99.35 and two dealer bids at 99.25 and 99.50. Every source sits near 99.40, none near 101.80. Re-striking with its median of 99.375 moves class I by 0.02 cents from the Driver's figure, so it agrees, 97% confident.
“Agreement within 0.1¢: the explanation goes to the analyst.”
On Quillfield Emerging Markets Equity Fund, inside policy, the Driver blames Northgate's London 4:00 p.m. Brazilian real rate of 5.4120 against the books' 4:00 p.m. ET rate of 5.4385. The Challenger, 71% confident, disagrees: a second ET source says 5.4150, close to Northgate, so the books' rate may be the outlier — the vendor's snapshot was taken during a 2.5-minute spike. Both workings sit side by side, and the choice is a person's: side with the Driver (R2), side with the Challenger (R3), or hold anyway (H1).
“An analyst decides which rate is right.”
Under Quillfield's NAV error policy NAV-EP-3, publishing as struck is a NAV error: every class rounds one cent high, class C two cents. From the day's 1,842 transactions, redeemers would be overpaid $66,047 and subscribers would overpay $42,056 — a net loss to the fund of $23,991, 0.128% of NAV. That is under 0.5%, so the fund would be made whole without reprocessing accounts. Holding and restriking before 6:00 p.m. costs nothing.
The Sizing agent shows its working; it never decides compensation and never signs.
Priya Raman proposed the hold at 5:38 p.m. with reason H1 — over policy, cause not yet confirmed by the administrator: the stale price is confirmed by two vendors and two dealers, and she agrees with the sizing. Maya, a different person as the rules require, approves it. All four classes are held from publication, and challenge Q-1016-07 goes to Northgate with five attachments.
“Meaning of this signature: I approve holding this NAV from publication.”
The Escalation agent drafted the challenge at 5:36 p.m. and sent it only after Maya approved: the 1.3-cent gap, the stale Corvane price, both vendors and both dealer bids, the issuer's notice in Portuguese and English, and a request to reprice and restrike before 5:55 p.m. ET. Jordan Ellis, Northgate's NAV control lead, answers through the administrator portal, where Northgate sees only the challenges addressed to it: repriced at 99.40, restruck at I 10.130, A 10.127, C 10.125 and R6 10.131.
“Confirmed: Corvane 5.25% 2029 price was stale in our dealer-quote feed.”
Release stays closed until the Shadow agent re-checks the restrike: class I 10.130 against a shadow of 10.129, the 0.1-cent fee timing difference, inside the band on all four classes. Maya releases at 5:54 p.m. with reason R4, restruck and re-verified, and the NAV is published at 10.13. The Evidence agent files prevented error PE-2026-023: 1.3 cents over policy, held for 14 minutes, $23,991 net loss avoided.
“It goes into the quarterly board report.”
For the board of Quillfield Funds Trust, the valuation designee and the audit committee: 21,760 share-class NAVs checked in the third quarter, 14 breaks over policy caught before publication, none published over policy, and a median restrike of 13 minutes. All 14 were held and restruck before the cut-off except one, published 14 minutes late on August 21. The draft lists the causes and the one past error the onboarding back-test found, every figure ties to the audit trail, and it goes to the treasurer for review.
“Every hold and release was decided by a controller other than the analyst who proposed it.”
The same evening of NAV oversight, seen by five of the people who carry it — what the hour before the cut-off looked like, and what it looks like now.
Seven agents shadow, explain, size and challenge every NAV; a controller holds or releases.
Collects each administrator's NAV pack — PDF summary, positions, prices, trial balance, capital activity — reads it in the language it is written, and checks every file against the delivery calendar and its schema.
Builds an independent shadow NAV for every share class from the manager's own books, the approved price hierarchy, FX at 4:00 p.m. ET, accruals, expenses and capital activity, and re-verifies every restrike before Release opens.
Splits every difference into price, position, accrual and income, FX, fair value, expense and capital activity, each driver cited to its source line — the pack, the vendor price, the issuer notice, the board minute.
Re-checks the Driver's main driver from a source the Driver did not use — the secondary vendor, dealer quotes, a second FX source — and agrees only within 0.1 cent; otherwise it says it disagrees.
Applies the fund's own approved NAV error policy: the published per-share error after rounding, the percentage of NAV, the net loss to the fund, the harm to subscribers and redeemers from the day's flows, and whether accounts are reprocessed.
Drafts the challenge to the fund administrator with the evidence attached, tracks the promised restrike against the cut-off and sends a reminder.
Keeps the audit trail complete, builds evidence packs, drafts the board report and correction memos, and finds repeat causes — 6 of the 9 price breaks since July came from Northgate's dealer-quote feed — to propose a stale-price rule.
Propose, hold or release, sign corrections. The agents propose; a named person decides.
Ask about a fund, a share class, an administrator or a decision — or tell the agents what to draft. Every answer cites its source, and anything that needs a decision goes to a person.
Which NAVs need me before the 6:00 p.m. cut-off?
Two funds. Quillfield Short Duration Fund: Northgate 10.142 against a shadow of 10.129, 1.3¢ over a one-cent policy, from a stale Corvane 2029 price; Priya Raman proposes a hold. Global Real Estate Securities: 1.1¢, a missed Hoshidai REIT distribution; restrike promised 5:50 p.m. Everything else is explained or inside its band.
What would publishing Short Duration as struck cost?
Under NAV-EP-3 it is a NAV error: every class rounds a cent high (class C two). From the day's flows: redeemers overpaid $66,047, subscribers overpay $42,056, a net loss to the fund of $23,991, 0.128% of NAV. Holding now costs nothing.
Lower the tolerance for this fund
I can't change a tolerance: agents never change a policy, and only the Head of Fund Accounting approves a new version. I drafted the request for Short Duration (its band today: one cent a share), attached the last 60 business days of gaps, and put it in Sign-offs for Hannah Lindqvist.
Draft the third-quarter board report on NAV oversight
Drafted from the record: 21,760 share-class NAVs checked in the quarter, 14 breaks over policy caught before publication, none published over policy, median restrike 13 minutes, and the one past error found by the back-test (NEC-2026-014). Opening the draft for the treasurer's review.
13 screens from the working solution, on its sample data. Pick one to see it large.
The thresholds every NAV is checked against are settings, read by the agents and cited to your policy section, versioned and approved by the Head of Fund Accounting.
| Setting | Default | Choose from |
|---|---|---|
| US funds and ETFs (NAV-EP-3) | $0.01 a share on the published NAV | 0.5% of NAV or more: reprocess accounts · less: the fund is made whole · shareholder payments under $10 not made |
| Luxembourg SICAV (CSSF Circular 24/856) | 0.2% money market · 0.5% bond and mixed · 1% equity | Over threshold: compensate investors, notify the CSSF |
| Irish ICAV, Singapore VCC and Cayman funds | 0.5% of NAV | Ireland: compensate, notify the Central Bank · Singapore: compensate investors · Cayman: board decides, investors notified |
| Inner band, where the agents must explain | Half the band edge — 0.5¢ for US funds | Market-event override O1: the Head may widen it for one day, with a reason |
| Cut-offs | Asia 6:30 a.m. · Europe 1:00 p.m. · Americas 6:00 p.m. ET | Escalate to the Head 10 minutes before the cut-off |
| Agent thresholds | Driver explains 90% of a gap · Challenger agrees within 0.1¢ · mapping at 95% confidence | A change becomes a new version for the Head to approve |
| Data residency and retention | US East · EU (Frankfurt) · Singapore | US funds 7 years (Investment Company Act books and records: 6) · Luxembourg SICAV and Irish ICAV 10 years · legal hold suspends deletion |
| Reason codes | Required on every decision | Hold H1–H3 · Release R1–R4 · Override O1–O2 · Correction C1–C3 · Reject X1–X3 |
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 data · “target” = the design goal, measured in the live solution · “estimated” = our estimate, including the analyst-days split · “typical” = published figures (SEC Rule 2a-5 adopting release: the $0.01-a-share and 0.5%-of-NAV benchmark called “not unreasonable”; SEC administrative proceeding, 2008: a $3.9 million penalty over mispriced municipal bond funds that cost shareholders about $60 million; CSSF Circular 24/856, effective January 1, 2025: NAV error thresholds by fund type). People, firms, funds, fund administrators, issuers and identifiers named on this page are fictional — characters and sample data in the working solution.
NAV oversight is an asset manager's own check of the net asset value its fund administrator strikes, because the liability for a wrong NAV stays with the manager and the fund board. In NAV Oversight, seven agents check each administrator NAV against a shadow NAV built from your own books, explain every break with its cited source, size it under your NAV error policy and draft the challenge; the controller asks them questions in plain words, reads the evidence and holds or releases each NAV before the cut-off.
A shadow NAV is an independent NAV built from the manager's own positions, independent prices, FX and capital activity, to compare with the administrator's. The Shadow agent builds one for every share class each cycle, so the team's NAV review runs by exception — the classes outside the inner band — instead of keeping a second set of books by hand.
The industry benchmark for US funds treats a NAV calculation error of a penny a share or more as a NAV error, and reprocesses shareholder accounts at 0.5% of NAV or more; the SEC called it “not unreasonable” in the Rule 2a-5 adopting release. Under the NAV error correction policy in the working solution, an error below 0.5% is corrected by making the fund whole for its net loss. The Sizing agent applies your own written policy class by class, and the treasurer signs the correction.
Each fund is checked against its own written NAV error policy. In the working solution, US funds at one cent a share, Luxembourg funds at the CSSF thresholds by fund type — 0.2% money market, 0.5% bond and mixed, 1% equity — and Irish, Singapore and Cayman funds at 0.5% of NAV. Each threshold is cited to its policy section, versioned and approved by the Head of Fund Accounting.
For NAV break analysis, the Driver agent splits each difference into price, position, accrual and income, FX, expense and capital activity, cited to the source line. In the demo it traces 1.2 of 1.3 cents to a bond the administrator had priced unchanged for five business days, with the issuer's Portuguese notice beside the English, and the Challenger agent confirms it from other sources.
The manager and the fund board: outsourcing the NAV does not outsource the liability. The SEC fined one manager $3.9 million over mispriced NAVs that cost shareholders about $60 million. NAV Oversight keeps the evidence of the manager's own check — every figure, decision and signature — on one audit trail, and records who pays when an administrator accepts liability for a correction.
Yes. The agents never hold, release, send, sign, change a price or change a tolerance. An analyst proposes, a different controller holds or releases, the treasurer signs corrections, and the Head of Fund Accounting approves policy versions and gives the second approval at 0.5% of NAV or more.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your NAV error policies, administrator agreements, price hierarchy and a sample of past NAV packs — and it goes live once every quality gate has passed. First-time setup ends with a back-test over the last 20 business days of administrator NAVs, to find anything already published over policy.
Every administrator graded on its evidence, with the cause of each error found and fixed.
1-min demoFund Expense AllocationEvery invoice split with its LPA clause, and nothing the manager owes charged to a fund.
1-min demoManagement Fee CalculationEvery fee recalculated from its clause before billing, every gap explained and signed.
1-min demoWe'll run NAV oversight on a past month of your own administrator NAV packs, books and NAV error policies.