WorkflowPortfolio Management & Manager Research

Operational Due Diligence

Operational due diligence you work through with seven agents: ask in plain words, approve every step, and see the independent source behind every claim

Every service provider checked against an independent source, before the commitment.

See one case, screen by screen ↓
demo146claimschecked on one manager against sources the manager does not control: 137 verified, 5 single source, 4 contradictions
demo38documents2,146 pages in English, French and German, read overnight, each in its own language
target100%of service provider claims checked against an independent source before the commitment
target10daysto sign a first review, against a 30-business-day service level
In short

What is Operational Due Diligence?

Operational due diligence (ODD) is an allocator's review of a fund manager's operations, controls and service providers before it commits client money and again every two or three years: who administers the fund, holds the assets, values the hard-to-value positions and audits the books, and whether the policies match what the manager says. Operational Due Diligence gives the ODD team seven agents that read the data room in any language, draw the operating structure, check every claim against an independent source and draft a cited ODD report. The analyst works with them in a conversation beside the work, asking why and opening each source, approves every confirmation, and submits a Pass, Conditional or Fail rating that the Head of ODD signs.

AI in asset management: a buyer's guide to agentic AI for investment managers →

Updated

The problem

Why operational due diligence still rests on the manager's word

Operational due diligence is the part of fund manager due diligence where an allocator decides whether a fund manager's operations can be trusted with client money: who administers the fund, who holds the assets, who values the hard-to-value positions, who audits the books, and whether the policies say what the manager says they say. Before every commitment, and again every 24 or 36 months, an ODD analyst collects the data room by email, reads the AIMA or ILPA DDQ, the offering memorandum, the audited financial statements, Form ADV and a dozen policies, some of them in French or German, draws the fund structure by hand and writes a report in Word that rates the manager Pass, Conditional or Fail.

Most of that report rests on what the manager says about itself. Checks against Form ADV Schedule D, the regulator's register and the audited notes are sampled, confirmation requests often go to contacts the manager supplied, and reused answers go stale: a new administrator or a departed principal can go unreported in the questionnaire. SEC examiners found private fund advisers that "did not value client assets in accordance with their valuation processes or in accordance with disclosures to clients". And once the committee approves, the conditions precedent to funding are often tracked in email.

demo248reviewsplanned this year by an ODD team of nine, across 436 approved managers
demo6reviewsalready past their service level, the oldest 5 days late
typical36%+of SEC-registered advisers manage private funds
Where an initial review's analyst days goestimated
By hand8 days
With the solution2 days
  • Collecting the data room and chasing missing documents1.5 → 0.3 d
  • Reading the DDQ, offering documents, financials and policies3 → 0.5 d
  • Drawing the structure and checking claims against independent sources1.5 → 0.5 d
  • Confirmations to the administrator, depositary, auditor and prime brokers0.5 → 0.3 d
  • Findings, rating and writing the ODD report1.5 → 0.5 d

Estimated split of the analyst days in one initial manager review, by hand and with the solution, from practitioner ranges of 6 to 10 analyst days per review.

How it works

How a manager review moves

Seven agents read the data room, draw the structure, check every claim and draft the cited report; the analyst submits, the Head of ODD signs.

What comes in
Manager in200+ reviews a year · data room, filings, registers; any language
Agents at work
Intake agentreads any language
Then
Structure agentdraws the structure
Policy agentpolicies vs standards
Then
Verifier agentindependent sources
Monitoring agentre-review triggers
Then
Findings agentcited report
Review agentchecks every citation
A person decides
Analyst, Head of ODDsubmit, then sign
What comes out
Structure verified
Rating signed
Funding gated
One case, step by step

One operational due diligence review, from data room to funding gate

Quillfield Capital's Multi-Manager Solutions team proposes a $150 million allocation to Fernhill Macro Fund SICAV-RAIF, a $2.41 billion Luxembourg global macro fund with a Delaware feeder, managed by Fernhill Capital Management LLP in London. Review ODD-2026-0417 is on day 11 of its 30, and the committee meets on October 29. Nadia Okafor works the review with seven agents: she asks them questions in plain words, they answer with the page behind every claim, and nothing is sent, submitted or signed until a person approves it. Here is what happens next, screen by screen, in the working solution.

  1. 01Tuesday, 8:40 a.m.

    The agents worked overnight; one thing needs her first

    Nadia Okafor · Senior ODD Analyst

    Nadia has 7 of the team's 41 reviews in progress; 6 reviews are past their service level, 3 ratings wait for sign-off and the Monitoring agent has raised 8 re-review triggers. Overnight the Intake agent read Fernhill's 38 documents, the Structure agent drew 10 entities, the Verifier checked 146 claims and the Findings agent drafted 2 findings with Conditional proposed. Each item under Needs you carries one next step, and an ask box under the agents' overnight log takes her questions.

    Needs you: “Fernhill Macro Fund: the administrator in the questionnaire is not the one in the audited accounts.”

  2. 02Open the structure

    The manager's operating structure, every entity checked

    Structure agent · Verifier agent

    The map shows the fund, its US feeder, the general partner, the AIFM, the investment manager, the valuation agent, the administrator, the depositary, the auditor and the two prime brokers, each with a verification ring. The administrator, Calder Fund Services (Luxembourg) S.A., shows 13 of 16 claims verified and two contradictions, with finding F-1 pinned to it. The prime brokers are partly verified while Ardent Prime's reply is awaited.

    “Drawn from 38 documents · each entity checked against a source the manager does not control.”

  3. 03She asks

    “Why is this a contradiction?”, answered with three sources

    Nadia Okafor and the Verifier agent

    Beside the map sits the agents' conversation about the administrator. Nadia asks why it is a contradiction. The Verifier answers that three sources the manager does not control agree with each other and not with the manager: audited note 2, Calder's own reply that its appointment ended February 28, and the regulator's register for Valmont. The questionnaire, dated August 14, five months after the change, still says no provider changed in three years.

    Next step, from the Verifier: “I drafted a confirmation request to Valmont … Nothing is sent until you approve it.”

  4. 04One click on the citation

    The French audit note says what the DDQ does not

    Verifier agent

    Nadia opens the source behind the answer. The DDQ, dated August 14, 2026, says Calder “has acted as the Fund's administrator since launch in 2019”, and Form ADV, filed March 27, 2026, names Calder at Schedule D question 26. Note 2 of the 2025 audited financial statements opens at page 14 in French beside the English: with effect from March 1, 2026, the Board of Managers of the General Partner appointed Valmont Fund Administration S.A., replacing Calder.

    Every source opens at its page, the original language beside the English.

  5. 05Approve and send

    A confirmation to Valmont, from the regulator's register

    Nadia Okafor · Senior ODD Analyst

    The Verifier's draft goes to client.oversight@valmont-fa.lu, the address in the Luxembourg regulator's register, and asks Valmont to confirm its appointment and start date, that it calculates the NAV and sends investor statements, the net asset value at September 30, 2026, and its 2025 SOC 1 Type II report, by October 27. Nadia approves it with reason code CF-01, signed with her name and the time; rejecting it would need a reason code and a note, send nothing and leave the Verifier to redraft from her note. Calder, the auditor and the depositary, the last in German, have already replied and been reconciled; Ardent Prime is due October 22.

    “The request goes to client.oversight@valmont-fa.lu, the address in the Luxembourg regulator register. The manager is not copied.”

  6. 06Findings and rating

    Two cited findings, and a second agent checks every sentence

    Policy agent · Findings agent · Review agent

    F-1 (High): the administrator change was not disclosed. F-2 (Medium): the valuation policy lets the portfolio manager override a Level 3 price and tell the Valuation Committee only afterwards, while the DDQ says the committee approves every Level 3 price; Level 3 is 6.8% of NAV, $164.0 million. Nadia can accept, edit or reject each draft with a reason, or raise her own finding from any entity. The Review agent finds 31 of 31 sentences cited and returns one note, applied to the draft: F-2 now states the Level 3 share.

    House rule: “a High finding blocks Pass; Conditional needs conditions precedent.”

  7. 07Submitted · signed

    The analyst submits; the Head of ODD signs Conditional

    Nadia Okafor and Evelyn Hartmann

    Nadia submits Conditional with conditions C-1 and C-2 for sign-off. She cannot sign her own submission. Evelyn Hartmann, Head of Operational Due Diligence, opens the rating, chooses Conditional and signs with reason code RT-02, “Conditions precedent to funding”. Her signature, its time and the reason are written to the audit trail.

  8. 08The report

    A cited ODD report, final once signed

    Findings agent · Review agent

    The operational due diligence report reads in five sections: summary, the structure, findings, observations and sign-off, with a sources index. Each entity in the structure shows what it was checked against and the result. The status reads Signed Conditional, 31 of 31 sentences cited from 25 sources, drafted by the Findings agent and checked by the Review agent; one click exports it to document management.

    “We rate the Fund Conditional. Its operating structure is sound and independently confirmed: the depositary, the auditor and the regulators’ registers agree with what the manager told us.”

  9. 09Thursday, October 29

    The committee decides; the money waits for both conditions

    Rajiv Menon · CIO and committee chair

    The Alternatives Investment Committee agenda holds six allocations, $535 million. Fernhill's ODD rating is read-only. The funding gate holds the $150,000,000 subscription to class I USD, dealing day December 1, 2026, in the order management system until Fund Operations clears C-1 and C-2 with evidence and the COO approves each clearance.

    “The committee decides the investment. It reads the ODD rating and cannot change it.”

  10. 10Across the approved list

    One provider, every manager that uses it

    Monitoring agent

    Calder administered 23 approved managers in January. Three have moved away this year: Brightwater, Saltmarsh and Ondine. Fernhill, under initial review, also left, and two of these managers did not tell Quillfield: Fernhill and Saltmarsh. Each of the three is a proposal with its source and the agent's confidence, from confirming the new administrator to an event re-review. Only the Head of ODD opens or dismisses one.

    “The agent proposes; only the Head of ODD opens or dismisses a re-review, with a reason code.”

Who it’s for

Built for everyone who signs off on a manager.

The same review, seen by five of the people who carry it: what their year looked like, and what it looks like now.

NO
Nadia OkaforSenior ODD Analyst · London · 28 reviews a year across Europe
Senior ODD Analyst
Before
Spends most of a review reading the data room and chasing documents by email, then checks a sample of claims by hand. “I don't need a summary of the DDQ. I need to know where the DDQ is wrong.”
Now
Opens a structure already drawn and checked, with 146 claims sorted into verified, single source and contradiction; asks the agents why, opens each source, and approves every confirmation before it goes.
EH
Evelyn HartmannHead of Operational Due Diligence · New York · signs every rating
Head of Operational Due Diligence
Before
Signs every rating and answers to the committee for any manager that later fails operationally, from reports that read differently by analyst. “If I sign Conditional, I want the two reasons and the two pages, nothing else.”
Now
Signs Conditional with the two findings, the two conditions and every page cited, a reason code on the record, and approves every new settings version.
RM
Rajiv MenonCIO, Multi-Manager Solutions · chairs the Alternatives Investment Committee
CIO, Multi-Manager Solutions
Before
Decides the allocations. “Tell me if ODD is a no before we spend an hour on the strategy.”
Now
Reads the signed ODD rating and its conditions on the committee agenda, records the investment decision subject to them, and cannot change the rating.
SL
Sophie LaurentCOO, Multi-Manager Solutions · London · owns the review program and funding
COO, Multi-Manager Solutions
Before
“Two hundred forty-eight reviews this year with nine people. Show me which ones are late and why.” Conditions precedent are tracked by email.
Now
Sees the 41 reviews in progress with their service levels and analyst workload, asks the Monitoring agent to propose a rebalance and decides the move, and approves every condition clearance before money moves.
GA
Grace AchterbergInternal Audit · New York · reads every file
Internal Audit
Before
Asks of every review file: “Who decided, on what evidence, and was it the same person who made it?”
Now
Asks the trail in plain words, such as whether anyone made and checked the same decision, filters it by person, agent or review, verifies the chain and exports the complete review file.
Built on the engine

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

Seven agents read the data room, draw the structure, check every claim and draft the cited report; the analyst submits, the Head of ODD signs.

Intake agent

Collects the data room, classifies every document by type, language, pages and date, reads it in its own language, with OCR for scans, lists what is missing and drafts the request for the analyst to approve.

  • Never accepts a document from an unverified sender
  • Never decides what is material
Structure agent

Draws the manager's operating structure from the offering documents, the DDQ, the audited financials and the registers: entities, roles, service providers, jurisdictions and dates.

  • Never adds an entity without a source
Verifier agent

Checks each claim against a source the manager does not control (Form ADV Schedule D, the audited notes, regulators' registers, controls reports), drafts confirmation requests with contacts from the regulator's register and reconciles the replies.

  • Never contacts a provider without the analyst's approval
  • Never uses contact details supplied by the manager
Policy agent

Reads the valuation, allocation, personal trading, cyber and continuity policies against the house ODD standards and finds where they contradict the DDQ.

  • Never rates; it flags
Findings agent

Drafts findings with severity and conditions precedent to funding, proposes the rating, and drafts the cited ODD report and the condition letter.

  • Never signs or sends
  • Below 85% confidence it asks the analyst
Review agent

Checks the Findings agent's draft: every sentence cited, every citation opens its passage, and no sentence contradicts a verified claim.

  • Never edits the draft; it returns it with notes
Monitoring agent

Watches approved managers through Form ADV amendments, audited financials, registers, controls reports, manager letters and news, proposes re-reviews and finds patterns across managers that share a provider.

  • Never opens a review on its own; the Head of ODD accepts or dismisses
Head of Operational Due Diligence

Signs Pass, Conditional or Fail. The agents propose; a named person decides.

Ask in plain words

Ask about any manager, provider or claim

Every review screen carries the agents' conversation beside the work. Ask about any entity, finding or review, or tell them what to draft. Every answer cites its source, and nothing is sent without your approval.

Why is this a contradiction?

Three sources the manager does not control agree with each other and not with the manager: audited note 2, Calder's own reply and the regulator's register for Valmont. The questionnaire, dated August 14, five months after the change, still says Calder and that no provider changed in three years.

Which other managers used Calder?

Calder administered 23 approved managers in January. Three moved away in 2026: Brightwater (disclosed), Saltmarsh (May 1, not disclosed) and Ondine (July 1); Fernhill, under this review, moved on March 1. I proposed a re-review step for each of the three.

How big is the Level 3 book?

Level 3 is 6.8% of NAV, $164.0 million, mainly emerging-market currency options and illiquid sovereign bonds. Under 15%, our standard rates a post-hoc override as Medium.

Draft the condition letter to Fernhill

“Before we fund, please provide (1) Valmont Fund Administration's written confirmation of its appointment and NAV services, its 2025 SOC 1 Type II report and the administration agreement, with a corrected questionnaire and a Form ADV amendment; and (2) an amended valuation policy requiring Valuation Committee approval before any Level 3 override, with the CIO recused.” It goes to the Head of ODD with the signed rating; nothing is sent from here.

Every screen

The working solution, as it ships.

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

TodayThe operational due diligence home for an ODD analyst: reviews in progress, past their service level, waiting for sign-off, re-review triggers, one next step each, and what the agents did overnight.
The operating structure mapThe manager's operating structure drawn from 38 documents, from the fund and its feeder to the administrator, depositary, auditor and prime brokers, each entity with its claims and independent checks.
Ask the agentsThe analyst asks why the administrator is a contradiction; the Verifier answers beside the operating structure with three independent sources and proposes a confirmation for her to approve.
French beside EnglishNote 2 of the audited financial statements opened at page 14, the French original beside the English, with the passage that contradicts the DDQ marked.
Approve a confirmationService provider due diligence in practice: the analyst approves the Verifier's confirmation request to the administrator, addressed from the regulator's register with the manager not copied, with a reason code and her signature.
Findings and the ODD ratingCited findings with severity and conditions precedent to funding, observations, the Review agent's citation check and the proposed ODD rating.
Sign the ratingThe Head of ODD signs Pass, Conditional or Fail with a reason code; the analyst who submitted the rating cannot sign it.
The cited ODD reportThe operational due diligence report section by section, each entity with what it was checked against, 31 of 31 sentences cited and a sources index.
Committee and funding gateThe investment committee agenda with the ODD rating read-only, and the funding gate that holds the $150 million subscription until both conditions are cleared and approved.
The manager review programThe manager review program: 41 reviews in progress of the 248 planned, with stage, analyst, service level and languages. Asked for a rebalance, the Monitoring agent proposes moving one late review to an analyst with capacity; the COO or the Head of ODD decides, with a reason code.
Monitoring and re-review triggersRe-review triggers on approved managers, each with its source and confidence, and the pattern at one fund administrator that four managers left this year.
The audit trailThe hash-chained audit trail of every person and agent action, with versions, reason codes and evidence. Internal Audit asks whether anyone made and checked the same decision; the Review agent answers: none of 297 maker-checker pairs.
Roles and segregation of dutiesWho approves, submits, signs, clears and releases in operational due diligence, with the segregation-of-duties rules; every settings version approved by the Head of ODD.
Governance

Built for fiduciary risk: verified, cited, signed.

Every claim cited, in its own languageEvery claim, finding and report sentence opens the page it came from. French and German sources are shown beside the English, and the Review agent checks that every citation opens its passage.
Independent sources, independent contactsEach claim is checked against a source the manager does not control. Confirmations go to the address in a regulator's register, never one the manager supplied, and only after the analyst approves.
Maker and checker on every ratingThe analyst submits; the Head of ODD signs Pass, Conditional or Fail with a reason code. The person who submits a rating can never sign it, and the committee reads the rating and cannot change it.
Funding waits for the conditionsConditions precedent become a funding gate in the order management system. Fund Operations clears each one with evidence and the COO approves the release; the same person cannot do both.
Agents propose, people decideAgents never contact a provider, send a letter, sign a rating, open a review or release money. Overriding an agent needs a reason code: agent misread the source, context the agent did not have, or policy exception approved.
Hash-chained trail, versioned agentsEvery person and agent action is on an append-only, hash-chained trail with version, reason and evidence, kept 7 years and exportable as one review file. A new agent version runs on 40 past reviews before the Head of ODD approves it.
Configuration

Your ODD standards, not ours

Your operational due diligence checklist, rating framework, review cycles, thresholds and service levels are settings. The administrator proposes a change; the Head of ODD approves each version.

SettingDefaultChoose from
Rating scalePass · Conditional · FailA Critical finding proposes Fail; a High finding blocks Pass, and Conditional needs conditions precedent to funding
House standards and questionnairesQuillfield ODD standards v7 (34 controls, 7 themes)AIMA (hedge funds) · ILPA (private equity) · house ODD questionnaire v7
Re-review cycleTier 1 every 24 months · Tier 2 every 36 monthsEvent triggers: a provider change, key person departure, qualified or emphasis-of-matter opinion, regulatory action, cyber incident, controls report exception
Agents ask a person below85% confidenceSet per agent from 70% to 99%; a new value is tested on 40 past reviews first
Service levelsInitial review 30 business days · re-review 20Sign-off within 3 business days; the Head of ODD alerted 5 business days before, the COO when it is missed
Confirmation repliesChase after 5 business daysIn-app and email; daily digest at 7:30 a.m. local time
Data residency and retentionUS East, with EU-sourced documents in EU West · review files kept 7 yearsRule 204-2 requires five; legal hold overrides deletion; exports watermarked with the recipient
Who signsHead of Operational Due DiligenceA deputy only with a recorded delegation
Connections

Works with the sources an operational due diligence review already uses

Manager data roomsAIMA or ILPA DDQ, offering documents, policies and controls reports, in any language
Audited financial statementsincluding their notes, in the fund's own language
Form ADV filings feedPart 1A Schedule D: auditor, prime brokers, custodians, administrator, valuation
Regulator and trade registersSEC, FCA and Luxembourg
Service provider repliesadministrators, depositaries, auditors and prime brokers, through email and their portals
Your systems of recordresearch management system, CRM, document management, portfolio accounting and the order management system
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
100%
of service provider claims checked against an independent source
every provider
Form ADV, audited notes, registers, replies
target
0
allocations funded with an open ODD condition
Todayconditions tracked by email
With agentsfunding gated until cleared
target
10days
to sign a first review, against a 30-business-day service level
Today30 business days
With agents≈ 10 business days

“demo” = seen in the working solution, on its sample data · “target” = the design goal, measured in the live solution · “estimated” = our estimate, from practitioner ranges · “typical” = published figures (SEC Office of Compliance Inspections and Examinations, Risk Alert, Observations from Examinations of Investment Advisers Managing Private Funds, June 23, 2020: more than 36% of SEC-registered advisers manage private funds, and the quoted finding on valuation). Form ADV Part 1A Schedule D Section 7.B.(1), SEC Rule 204-2, the AIMA and ILPA due diligence questionnaires and SOC 1 Type II reports are named as the forms and standards the work follows. People, firms, funds, service providers and identifiers named on this page are fictional — characters and sample data in the working solution.

Questions

What allocators ask about operational due diligence.

What is operational due diligence?

Operational due diligence (ODD) is an allocator's review of a fund manager's operations, controls and service providers before it commits client money and again every two or three years: who administers the fund, holds the assets, values the hard-to-value positions and audits the books, and whether the policies match what the manager says. Operational Due Diligence gives the ODD team seven agents that read the data room in any language, draw the operating structure, check every claim against an independent source and draft a cited ODD report. The analyst works with them in a conversation beside the work, asking why and opening each source, approves every confirmation, and submits a Pass, Conditional or Fail rating that the Head of ODD signs.

How is hedge fund operational due diligence different from private equity?

Hedge fund operational due diligence and operational due diligence in private equity follow the same method with different questionnaires and structures: the AIMA DDQ for hedge funds, the ILPA DDQ for private equity managers. In the working solution the review program covers hedge fund, private equity, private credit, infrastructure and real asset managers, and the questionnaire templates are AIMA, ILPA and the firm's own operational due diligence questionnaire.

What does an operational due diligence report include?

The report the agents draft has five sections: a summary with the rating, the structure with what each entity was checked against, the findings with their conditions precedent to funding, the observations and the sign-off, followed by a sources index. Every sentence is cited; the Review agent checks each citation before the analyst submits, and the report is final only once the Head of ODD signs.

How does it verify a fund's administrator and other service providers?

Service provider due diligence, fund administrator due diligence included, is where the independent checking happens. For the administrator and every other provider, the Verifier agent checks each claim against sources the manager does not control: Form ADV Part 1A Schedule D, the audited financial statements' notes, the regulators' registers and the provider's own controls report. It drafts a confirmation request to each provider with the contact from the regulator's register, the analyst approves it before it is sent, and the reply is reconciled to the claims.

Can it read documents in French, German and other languages?

Yes. The Intake agent reads every document in its own language, with OCR for scans. In the demo it read 38 documents, 31 in English, 4 in French and 3 in German, and every source opens with the original beside the English, so a contradiction in a French audit note can be read against the English DDQ.

Do people stay in control of the rating and the funding?

Yes. The agents propose and never contact a provider, sign a rating, open a review or release money. The analyst approves every confirmation, accepts, edits or rejects each drafted finding with a reason and submits the rating; the Head of ODD signs it; the investment committee decides the investment without being able to change the rating; and Fund Operations and the COO clear each condition before the subscription is released.

Does it watch managers after they are approved?

Yes. The Monitoring agent watches approved managers through Form ADV amendments, audited financials, registers, controls reports, manager letters and news, and proposes re-reviews with their source. When one provider changes or its controls report is qualified, it shows every approved manager that uses it. Only the Head of ODD opens or dismisses a re-review.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents: your ODD standards, rating framework, questionnaires and a sample of past signed reviews. It goes live once every quality gate has passed, including a test of the agents against your past reviews. We will walk you through it on your own managers first.

See it on
your managers.

We'll run Operational Due Diligence on a sample of your own past manager reviews and data rooms.