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AIMA QUESTIONNAIRE
Due Diligence
Incorporating the AIMA Questionnaire
IDS is a member of AIMA
January 2014
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
1
ILLUSTRATIVE QUESTIONNAIRE FOR DUE DILIGENCE
OF
HEDGE FUND ADMINISTRATION FOR
MANAGERS
Illustrative Questionnaire for Due Diligence of HEDGE FUND ADMINISTRATION FOR MANAGERS The purpose of this document is to serve as a guide to managers in their relations with hedge fund administrators. Not all of the following questions are applicable to all administrators but we recommend that you ask as many questions as possible before making a decision.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
2
Illustrative Questionnaire for Due Diligence of HEDGE FUND ADMINISTRATION FOR MANAGERS
CONTENTS Items Page No.
............................................................................................................................ 2 Contents
1 Details of Administrator ................................................................................................... 3 2 Ownership .................................................................................................................... 4 3 Documentation .............................................................................................................. 5 4 Size of Operation/Group .................................................................................................. 5 5 Client Relationship Management......................................................................................... 6 6 Auditors ...................................................................................................................... 7 7 Operations ................................................................................................................... 8
7.1 Shareholder Registration ............................................................................................ 8 7.2 Administation.......................................................................................................... 9 7.3 General ................................................................................................................. 9 7.4 Communication ...................................................................................................... 10 7.5 Other (please describe) ............................................................................................ 10
8 Equalisation ................................................................................................................. 10 9 Compliance Checks ........................................................................................................ 10 10 Anit-Money Laundering ................................................................................................... 11 11 Insurance.................................................................................................................... 12 12 Regulatory Body/Authorisation ......................................................................................... 12 13 Payment and Signatory Procedures .................................................................................... 13 14 NAV Calculation ............................................................................................................ 13
14.1 Transations ........................................................................................................... 13 14.2 Corporate Actions ................................................................................................... 16 14.3 Pricing/Valuations ................................................................................................... 16
15 Reconciliation .............................................................................................................. 18 16 Front or Middle Office Services ......................................................................................... 18 17 Fund Accounting System ................................................................................................. 19 18 Reporting .................................................................................................................... 20 19 Fund Systems Audits ...................................................................................................... 21 20 Legal and Tax .............................................................................................................. 21 21 Corporate Secretarial and Directors Services ........................................................................ 22 22 Fees .......................................................................................................................... 23 23 Operational Risk ........................................................................................................... 23 24 Business Continuity/Disaster Recovery ................................................................................ 24 25 General – Staff ............................................................................................................. 25
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
3
NB: THE INFORMATION GIVEN HEREIN IS CORRECT AS AT TUESDAY, 04 FEBRUARY 2014
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1 DETAILS OF ADMINISTRATOR 1.1 Name:
Investment Data Services (Pty) Ltd (Reg No. 2002/030790/07) Trading as IDS
Fund Services
1.2 Address:
Physical Address:
IDS House , 8 St.George’s Mall, Cape Town 8001
Postal Address:
P O Box 24, Cape Town 8000
1.3 Telephone:
+ 27 21 402-1600
1.4 Fax:
+ 27 86 574-8893
1.5 Website:
www.idsfundservices.com
1.6 Contacts:
1.6.1 Relationship Manager:
o Name:
o Telephone:
o E-Mail:
Tony Christien
+27 21 402-1600
1.6.2 Valuations/Fund Accounting:
o Name:
o Telephone:
o E-Mail:
Kosie Feyt
+27 21 402-1600
1.6.3 Custody
o Name:
o Telephone:
o E-Mail:
Leeann Scott
+27 21 402-1600
1.6.4 Financial Reporting:
o Name:
o Telephone:
o E-Mail:
Brenda Doyle
+27 21 402-1600
1.6.5 Operations Management:
o Name:
o Telephone:
o E-Mail:
Tony Christien
+27 21 402-1600
1.6.6 Shareholder Services/Registrar &
Transfer Department:
o Name:
o Telephone:
o E-Mail:
Mandy-Lee Feyt
+27 21 402-1600
1.6.7
Middle Office Services
Graeme Rate
021-402-1600
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
4
1.6.8
I.T. Systems:
o Name:
o Telephone:
o E-Mail:
Andrew Frankish
+27 21 402-1600
1.6.9 Please provide Personnel Chart with total number of staff, CVs of all Principals, Directors, Officers and Senior
Managers, including:
Board of Directors
Chairman/President
Managing Director/CEO
Finance Director
Marketing Director
Non-Executive Director(s)
Operations Management
1. Relationship Manager
2. Administration / Accounting
3. Shareholder Services / Registrar and Transfer Department
4. Compliance / MLRO
5. I.T.
6. H.R.
7. Company Secretary if appropriate
Refer to the attached “Investment Data Services Information Brochure – September 2013” for details.
2 OWNERSHIP 2.1 Parent company (if any):
Name:
Address:
IDS Group (Pty) Ltd
IDS House , 8 St.George’s Mall, Cape Town 8001
2.2 If privately owned, details of beneficial
owners:
IDS Group is privately owned by Individuals and Staff.
2.3 Please describe corporate and capital
structure of parent company:
IDS Group is a SA registered proprietary limited company.
2.4 Please describe corporate and capital
structure of the administrator:
IDS is a SA registered proprietary limited company.
2.5
Please give details of staff turnover for
the last 3 years showing levels of
seniority:
Cape Town
Since the 1st March 2008 to 31 December 2013 the IDS Group has had 146 new
appointments and 97 staff left the company.
Four of the staff leaving the company were senior staff members. One new
senior staff member joined the company.
Malta
Since 17 May 2010 to the 31 December 2013, 9 staff has been appointed and 2
staff members left the company.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
5
3 DOCUMENTATION
3.1
IDS can provide these documents upon specific client requests and signing of a non-disclosure agreement:
1. Audited financial statements of
a. Parent company/group consolidated; and
b. Administrator
2. Copy of Memorandum and Articles of Association of Administrator
3. Certificate of Incorporation of Administrator; or
4. Other statutory incorporation/formation documentation of Administrator
References:
1. Bank references; and
2. Two client references
4 SIZE OF OPERATION/GROUP 4.1
Is your office the sole office/head
office?
If no, list other offices:
IDS Fund Services head office is in Cape Town
IDS Fund Services Malta Ltd (Reg No. 49663) the office is located in Birkirkara,
Malta
The information shown below is for both entities combined.
4.2
What are total funds* under
administration of group?
Dec 2013 Dec 2012 Dec 2011
Dec 2010
Dec 2009
ZAR 80
Billion
ZAR 54,2
billion
ZAR 39,40
Billion
ZAR 33,7
Billion
ZAR 33,7
Billion
4.3 What proportion of total funds under
administration relates to alternative
investments? 93% 96% 100% 100% 100%
4.4 What are total funds* under
administration of your office?
ZAR
80 Billion
ZAR 54,2
Billion
ZAR 39,40
Billion
ZAR 33,7
Billion
ZAR 33.5
Billion
4.5 How many funds* are administered by
the group? 211 205 203
171
167
4.6 How many alternative investment funds
are administered by the group? 197 205 203
171
167
4.7 How many funds* are administered by
your office? 197 205 203
171
167
Please identify the Fund Strategies that you
administer (Convertible Bond/Pan Euro L/S etc.)?
IDS is able to support all hedge fund strategies and has a broad client base with funds investing in a wide range of securities. We service high yield funds, distressed funds, arbitrage funds, and emerging market funds, funds with a high component of derivatives, fixed income funds, and long/short equity funds.
4.8 If the fund is a Fund of Funds (FOF), how
many FOFs are administered by the
group?
60 65
50
38
38
4.9 If the fund is a FOF, how many FOFs are
administered by your office?
60 65
50
38
38
4.10 Provide breakdown of total funds under
administration by alternative investment
strategy.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
6
4.11 Provide breakdown of total fund
numbers by alternative investment
strategy.
4.12
Break down number of funds* for which
you provide daily, weekly, monthly,
quarterly and annual valuations.
DAILY WEEKLY MONTHLY QUARTERLY ANNUALLY
35
10
200
3
-
* Including sub-funds
4.13 How has the headcount grown during
the last 3 years?
2013-113
2012- 96
2011 - 91
2010 - 90
2009 - 91
2008 – 92
2007 - 65
2006 – 45
5 CLIENT RELATIONSHIP MANAGEMENT 5.1 Describe client relationship procedures:
For all clients, we appoint a Client Service Manager (CSM) who is responsible
for client interaction and is the “point” person for the relationship. The CSM is
responsible for all aspects of service delivery in the day-to day support of the
client.
This structure gives our clients a single contact point across all aspects of our
servicing teams.
5.2 Do you have a Client Relationship
Manager or equivalent?
Yes, see 5.1 above.
5.3 Who will be Client Relationship Manager
(or equivalent) allocated to our fund?
Why was this person chosen?
Yes, see 5.1 above.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
7
5.4 Describe client relationship services that
would be expected:
1. During pre-launch and set-up of
fund:
2. During on-going operation of the
fund:
3. Availability on day-to-day basis – i.e.
how many other funds/clients will
the Client Relationship Manager be
responsible for?
4. What will be back-up during
illness/vacations?
During the pre-launch / set-up stage
Within IDS, the marketing phase of the engagement is handled by the Client
Services team. Once a prospective client has made contact, a project
identified and a fee schedule accepted, the Business Implementation team
coordinates the setup of the fund and completes the required due diligence on
the fund and related entities.
During transition
The Business Implementation team will assist the client during the
transition/launch period. Whilst the Client Services Manager (CSM) will
develop the new relationship and oversee the transition process, the BIM will
plan the transition and make sure that all Client Service Units are ready to
take on and service the new Fund. The CSM (in the case of an existing client
relationship) is specifically appointed to handle the launch of a complex
project (e.g. Hedge fund with pooling and equalisation procedures).
On a day-to-day basis
Whilst the CSM performs a continuous oversight of the relationship and
manages any changes in client requirements or new product needs, a Fund
Account Manager (FAM) and Officers and their operational teams handle day-
to-day servicing. Key Client Service functions such as Accounting & Valuation
and Custody/Settlement are organised by Product type. In each unit, Fund
Account Managers are appointed to focus on the day-today contacts with the
clients. We believe that this dual structure CSM/FAM is the most effective way
to acquire an in-depth knowledge of the business conducted by a client and to
satisfy requirements at different levels of seniority.
Availability CSMs work flexible hours, with core hours being 8.30 am to 5.00 pm. In case of
special circumstances or emergency, CSMs are contactable by phone or mobile
phone.
Back-up The CSM roles involve cross-information processes to ensure that day-to-day
activities can be covered at all times by the replacing manager. It is also
encouraged that holidays should be taken at moments of lesser client historical
activity. In these processes, we also place heavy emphasis on co-ordinated
team building and consequently, require a high level of pro-activity from the
individual teams in their responses to client needs.
6 AUDITORS
6.1 Name of Company: Price Waterhouse Coopers
6.2 Contact Name: Zuhdi Abrahams
6.3 Telephone: +27 21 529 2342
6.4 E-mail: [email protected]
6.5 When appointed: March 2006
6.6 Have they always been your auditors?
If not, who were your previous
auditors?
When did you change and why?
No
Ernst & Young
March 2006, following a consolidation of auditors across the IDS Group
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
8
7 OPERATIONS What services do you provide? In particular, please comment on / describe the following:
7.1 SHAREHOLDER REGISTRATION:
Handling subscriptions and
redemptions (including
approval, issuing contract
notes and certificates, if
required):
Describe how your system
processes
shareholder/partner
activity
IDS places a great amount of importance on efficient and effective investor communications and
management reporting. When corresponding with the shareholders of a fund, IDS represents the
investment manager and promoter of the fund and it is essential that investors receive timely responses
to queries and statements that are easy to understand.
When the investor decides to make a subscription, the necessary completed documents will be sent
to the Investor Services department, where they are reviewed for completeness and accuracy, and to
ensure that the fund requirements (i.e. investor eligibility, minimum investment amounts, cut-off
times) have been met. A check will be done to determine whether the investor is an existing or new
customer. If new, the administrator will set up the new customer record on our share register system.
Systematic controls are in place to ensure that all instructions are issued to the respective fund within
the prescribed deadline. Standard procedure is as follows:
All subscriptions will be sent to us, initially by fax or email, prior to the cut off time stated in the fund’s
prospectus/partnership agreement. In the case of an initial subscription or any redemption we also
request that the original be sent to us by post. Once the fax/email is received, all details are checked
to ensure that they comply with the fund’s parameters. At this stage we can send an acknowledgment
to the shareholder/partner stating that the trade has been received and will be processed for the
relevant dealing day. If this is an initial subscription for a shareholder/partner, we will also review the
necessary anti-money laundering checks at this stage if requested to do so by the fund manager.
For subscriptions the cash availability is confirmed before it is processed (unless there is an allowable
exception).
The final stage of the process for subscriptions is the “completion” of trades. We will not perform this
until all relevant documents have been received, to ensure that our records show a complete and
correct audit trail. For redemptions a series of checks must be performed before a redemption can
be paid out (for example signatures are checked for authenticity and the current fund status checked to
ensure that redemption will not lead to the fund holding below the minimum level). We will also ensure
redemptions are in line with anti-money laundering (AML) procedures. Once the NAV has been received
and there are sufficient funds available in the funds account, payment will be made to the investor.
During the above process, detailed information can be sent to the investment manager, such as a trade
report detailing all trades received for a given dealing day at the cut off time for receipt of
subscriptions into the fund’s bank account). Pending trades are investigated to ensure that the
appropriate follow up process is adhered to.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration for
Managers (2007)
9
7.1.2 Processing receipts of
subscriptions and payment of
redemptions:
Any issues or outstanding documents are followed up with the either the investor or
fund manager.
All new investors are reviewed for compliance with AML regulations (Client is
responsible to obtain such evidence). For individual investors, we may require a copy of
their passport or identification card duly certified by a notary public, together with
evidence of their address such as utility bill or bank statement in the investor’s name.
In the case of corporate applicants we may require a certified copy of the certificate of
incorporation, memorandum and articles of association (or equivalent), the names,
occupations, dates of birth and residential and business addresses of all directors. (All
requirements in terms of FICA.)
7.2 ADMINISTRATION:
7.2.1 Can you act for:
1. Partnerships, LLPs?
2. Investment Companies?
3. Unit Trusts?
4. Master Feeder Fund
structures?
IDS can administer all of these structures.
7.3 GENERAL
Please provide information on your processes for:
7.3.1
Publishing Net Asset Value
and/or share prices, if there is
a bid/offer spread:
Not yet in South Africa
7.3.2 Preparation of financial
statements:
As part of the valuation process, IDS prepares unaudited financial statements (i.e.,
Balance Sheet, Income Statement, and Statement of Changes) for each valuation
period.
At year-end, IDS will produce a set of financial statements based on the required
reporting framework. These are then audit by the external auditors and any changes
requested by the auditors are effected where necessary.
7.3.3 Liaising with fund’s auditors:
IDS have extensive interaction with the auditors of each fund.
IDS Facilitate the audit by hosting the auditors at our offices and by providing all
necessary files and records to support them in their duties. IDS does all that is within
our power to ensure timely completion of audits. The majority of the audit work is
performed at the IDS offices as the client files are maintained onsite and is conducive
to a close working relationship.
7.3.4 Can you provide US tax
reporting (i.e. K1’s, etc.)?
Not required by existing client base.
7.3.5 Communication with
shareholders, regulators, data
services, stock exchange (if
applicable), etc.:
Not yet required by existing client base.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
10
7.4 COMMUNICATIONS
7.4.1
How do you report to investors
and investment managers?
FAX E-MAIL WEB PLATFORM
7.5 OTHER (PLEASE DESCRIBE)
a) Fund Fact Sheets: IDS produces monthly Fact Sheets, should these be requested by clients. These sheets contain all of the basic fund
information in a snapshot form, allowing the investor to obtain an understanding of the fund. The Fact Sheets are attached to the
Monthly Statements, which are sent to each investor in the fund.
b) IDS also administer private equity funds: more detail can be provided on application.
7.5.1
Please give details of
alternative investments and
hedge fund strategies that you
can support:
IDS are able to support all hedge fund strategies.
IDS have a broad client base with funds investing in a wide range of securities. IDS
can service high yield funds, distressed funds, arbitrage funds and emerging market
funds, funds with a high component of derivatives, fixed income funds, and long/short
equity funds
7.5.2 Do you administer funds
utilising the following strategy?
(to be completed by Manager):
Refer 7.5.1. IDS administer hedge funds, CIS and Private Equity Funds, including funds
of funds for all categories. Local and offshore funds are administered.
8 EQUALISATION 8.1
Do you provide equalisation
accounting services (including
the series of shares and
consolidation method)?
We can provide equalisation accounting services.
8.2 If so, please describe all
methods covered:
To be discussed with client during the set-up phase.
8.3 When carrying out equalisation
is this done on a separate
spread sheet system or is it
automated within your
mainstream administration or a
separate system?
This is automated within PFS-Paxus.
9 COMPLIANCE CHECKS 9.1 Do you carry out compliance
checks with regard to the
investment restrictions and
other restrictions of funds that
you administer, including,
inter alia:
1. Restrictions on minimum
investment by subscriber?
2. Leverage restrictions?
3. Investment restrictions:
a. Limits on size of
It is not IDS policy to carry out fund compliance checks at all.
No
No
No
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
11
individual
holdings?
b. Limits on exposure to
individual market or
individual
investment/issuer of
securities?
4. How frequently and how
promptly do you monitor
investment restrictions?
5. Valuation procedures, as
stated in the OM (Offering
Memorandum)?
6. Compliance with stock
exchange “Continuing
Obligations”?
7. Others?
No
n/a
n/a
n/a
n/a
Are compliance checks
manually or system driven? If
system driven, please describe
the process and controls for
setting-up the appropriate
compliance checks and the
periodic review of any
restrictions:
n/a
10 ANTI-MONEY LAUNDERING 10.1
Do you take responsibility for
carrying out anti-money
laundering checks on Investors?
Depending on the terms specified in the Administration Agreement, the IDS Investor
Services and Compliance teams are involved in monitoring developments in anti-
money laundering (AML) regulations. The IDS office is in full compliance with the
AML requirements of SA (FICA). IDS partners with its clients to assist them in
developing an AML program that both suits their individual risk level and complies
with all applicable AML regulations.
Some of the AML compliance services which IDS can assist with are:
1. Obtaining or checking identifying and due diligence documentation on potential
investors when necessary
2. Checking potential and current investors against the OFAC watch lists and other
relevant data bases
3. Monitoring investor activity and generating Suspicious Activity Reports when
necessary
4. Generally complying with all the requirements of FICA in South Africa.
Note: The client remains responsible for AML.
10.2 Please provide a summary of
your AML procedures.
Please see answer noted above.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
12
10.3 Please also supply details of
the guidelines or regulations
with which you are required to
comply.
Please see answer noted above.
10.4 Have your procedures been
subjected to external review
i.e. by the auditors and if so
when?
Please see answer noted above.
10.5
Who is your AML Officer?
Liza Fourie (Cape Town)
11 INSURANCE 11.1 Do you currently hold
insurance for the following:
Director & Officers
Liability?
Professional Indemnity?
Crime (Employee
fidelity/third party fraud)?
Key Person Insurance?
Other?
N.B.: if you are not restricted
from disclosing such
information under your
policy(ies)
IDS maintain insurance coverage for its own protection at levels that it believes is
appropriate and sufficient for the types of business conducted. These covers are placed
with excellent security within recognised markets providing insurance to financial
institutions. As would be expected for IDS, the policies include: (1) Errors & Omissions
insurance which is professional indemnity cover for mistakes, errors, omissions and
negligence etc.; and (2) Comprehensive Crime, which is a combination of Blanket Bond
and Computer Crime Policies for infidelity, fraud, theft, damage to and loss of property
and related risks. Key person insurance is also in place for senior executives.
12 REGULATORY BODY/AUTHORISATION 12.1
Who is your regulator?
IDS (Pty) Ltd is a category I FSP under the FAIS and as such is regulated by the FSB.
IDS Fund Services Malta Ltd is a recognised Fund Administrator by the Malta Financial
Services Authority.
12.2 Contact name: Financial Services Board (www.fsb.co.za)
12.3 Authorisation status: Active
12.4 Authorisation number: FSP number 16802
12.5 If a group, is this your main
regulator or are you subject to
regulation by a regulator in
another jurisdiction?
The FSB is the main regulator, but IDS Malta is subject to regulation by the MFSA
12.6 When was the last regulator
visit/audit and were any
material issues identified? If
yes, what was the nature of
the issues(s) and how long did
they take to be resolved?
The most recent FSB visit took place from the 11th to 14th July 2011.
12.7 Has the administrator been
subject to any regulatory
disciplinary actions?
No
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
13
12.8 If so, please describe
circumstances, what was done
to remedy the situation and
current regulatory status of
administrator:
N/a
12.9 Is your company a member of
AIMA or any other relevant
trade association?
Yes, AIMA, SAVCA (South African Venture Capital Association), ASISA, and ACCA.
13 PAYMENT AND SIGNATORY PROCEDURES 13.1 Third party payment
procedures:
1. Do you have signing powers
with regard to third party
payments on funds for
which you act as
administrator?
2. Do you have sole signing
powers or is it jointly with
the investment manager?
3. Does the investment
manager have sole
signatory powers?
Yes
Sole – but on instructions from the Investment Manager. (No discretion)
The Investment Manager issues instructions to IDS, but has no signatory powers over
the custody bank account.
13.2 Are you involved in authorising
the fund to open new
brokerage or bank accounts or
is this the sole responsibility of
the investment manager?
Custodian Bank Accounts are opened on instructions of the manager.
Brokerage accounts are opened by the Manager.
13.3 If you give third party payment
instructions on behalf of the
fund, what controls do you
have to ensure that only
authorised payments are made
(call
back/confirmation/other)?
Written or electronic instructions from the Fund Manager (no discretion).
Strict internal controls and division of duties together with dual sign-off procedures,
using EFT.
13.4 Can you provide a director for
the fund, with signatory
powers?
No
14 NAV CALCULATION
14.1 TRANSACTIONS
14.1.1
How often can you value the
portfolio(s)?
* - tends to be the norm
DAILY WEEKLY BI-WEEKLY MONTHLY QTR
LY
ANNUALLY
Yes,
mostly
portfolio
valuation
s, not
prices
Yes* Yes Yes* Yes Yes
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
14
14.1.2
Please describe how you
receive information with
regard to posting
security/investment
transactions:
IDS are able to receive daily information files from our clients and various
counterparties.
We receive our primary information from the Prime brokers via email and FTP. Since
we service funds that use more than one Prime Broker, multiple Prime Broker
interfaces is not an issue.
IDS utilises a middleware application (Medius) which allows us extreme flexibility over
incoming files. All incoming files (Client file, prime broker file, etc.) are translated
into a format which can be seamlessly uploaded into the administration system.
Broker and client files are received daily, weekly, and monthly. Outbound data is
equally as flexible.
14.1.3
Please describe your procedure
for establishing security
masters:
During the Market Data trade upload process, new securities are identified during the
actual trade upload process. Once any new security is identified, all listed info for
that security will be gathered, a security master is created and upload process is
continued.
14.1.4 What security identifiers are
used for exchange-traded and
non-exchange traded
securities?
Exchange-Traded securities identifiers include: ISIN, Ticker, SEDOL, CUSIP, RIC code
Non Exchange-Traded securities generally don’t utilize security identifiers.
14.1.5 If you receive the information
from the investment manager
or the prime broker or
custodian, do you:
1. receive the information by
fax or e-mail?
2. get hard copies direct from
the prime broker and/or
custodian?
Please see the response to the above question. Our preference is to receive
information from Investment Managers and Prime Brokers electronically. If this is not
possible, then we can receive the information by fax.
14.1.6 If the valuations are provided
by the manager or by one
issuer without independent
verification, is or will the
valuation procedure be
adequately described in the
OM and has it been or will it be
approved by the auditor?
IDS will not accept non-independent valuations. Where the manager has been
involved in making an estimate, independent verification is always obtained where
possible.
14.1.7 Do you book all trades on your
systems or rely on broker
statements?
IDS rely on Broker Statements and Trade files, which are used to upload into our
Accounting System. (IDS doesn’t book trades)
14.1.8
List security types which can
upload automatically into your
accounting system:
1. Equities
2. CFD’s (Contract for Difference)
3.Options
4. Commercial Papers
5. Bonds
6. Futures
7. Mutual Funds
8. Partnerships Interest
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
15
14.1.9 List security types which are
either input manually or input
as other security types:
To be discussed with client to determine needs.
14.1.10 Do you give any trading
instructions on behalf of the
investment manager? If so,
how do you receive those
instructions and from which
party?
IDS do not give any trading instructions on behalf of the Investment Manager. On
occasion, IDS may request a prime broker to create liquidity for redemptions, on
instructions from the Manager.
14.1.11 How do you confirm that they
are correct?
Written instructions, where relevant, are received from Managers. IDS has no
discretion, it only executes instructions. See above reply for scope.
14.1.12 Describe your procedures for
accounting for realised and
unrealised gains/(losses) on
forward currency contracts
entered into to hedge non-base
currency classes:
Hedge transactions are captured as FX transactions on the administration system. The
administration system automatically calculates realised and unrealised gains and
losses by marking the deals against the NAV date closing rates in the system. Exchange
rates and forward rates are via automated pricing feed into the administration
system.
14.1.13 What information will you
provide the manager in respect
of hedging non-base currency
classes?
N/A
14.1.14
How do you receive
information on cash
movements, including
payments and settlements of
transactions in the fund’s
accounts?
For information on the cash and securities transactions taking place through the fund’s
prime brokerage account, please see the response in 14.1.2.
All other cash movements and payments into/out of the fund’s account with
Investment Data Nominees Trust (IDNT) will be processed through our system and
automatically captured.
14.1.15 Please describe, in general
terms, the allocation of fund’s
expenses:
All income & expenses are allocated in accordance with the capital base of each
investor.
14.1.16 What percentage of your NAVs
are sent to managers within:
1 to 3 days?
4 to 5 days?
6 to 8 days:?
Timeframe Single Funds Fund of Funds
1 to 3 days 45% N/A
4 to 5 days 45% N/A
6 to 8 days 10% 100%
14.1.17 What percentage of NAVs are
agreed within:
1 to 3 days?
4 to 5 days?
6 to 8 days?
Timeframe Single Funds Fund of Funds
1 to 3 days 20% N/A
4 to 5 days 60% N/A
6 to 8 days 20% 100%
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
16
14.2 CORPORATE ACTIONS
14.2.1
Do you have a centralised
corporate actions department?
It forms part of the Market Data function.
14.2.2
Describe your procedures for
processing corporate action
activity.
On a weekly basis, dividends are automatically uploaded into Paxus, utilising an
automated feed from Bloomberg. Corporate Events such as Stock Splits and Capital
Reductions are manually inputted using local market sources.
Other than Bloomberg, the most comprehensive listing of Corporate Actions/Dividends
is the ABSA Corporate Diary. Other than the ABSA Corporate Diary (which is updated
weekly), the JSE and Sharedata are updated daily. ABSA, JSE and Sharedata are
continuously monitored. Once a new Corporate Action has been identified, and all
information has been gathered and confirmed, the Corporate Action is entered into
the Accounting System.
14.2.3
What corporate action
information sources do you
use?
1. Bloomberg
2. JSE
3. Sharedata
4. ABSA Corporate Diary
14.3 PRICING/VALUATIONS
14.3.1
Is the pricing of investments in
the fund independent?
Yes, we use independent sources for pricing investments in funds where possible.
14.3.2
Please describe pricing
source(s):
The accounting system, PFS-Paxus, takes an automatic price feed from Bloomberg. The
Investment Price Variance Report will detail all price sources as well as price variances
to the previous valuation or acquisition price, if more recently brought onto the
portfolio. To verify pricing where discrepancies exist, IDS consults additional sources
such as Telekeurs(foreign) and Sharedata(Local) or pricing vendors.
14.3.3 How do you handle valuations
of complex derivative
instruments when only the
manager and/or the
issuer/dealer claim ability to
value the assets?
We obtain a third party valuation from a source independent of the fund manager,
usually either the counterpart or the prime broker.
14.3.4
Do you ever outsource
valuations or pricing of
complex investment products
to independent specialists?
Only as above
For OTC instruments such as SWAPS, options etc., IDS has contracted a third party
vendor to confirm the prices on request.
14.3.5
What time can the manager
expect to receive net asset
value calculations?
DAILY WEEKLY MONTHLY
By 16h00
next day
From as early as the
Wednesday, with all net
asset value calculations
concluded by COB on the
Friday.
Single Funds 5th working day of
month
Fund of
Funds
7th – 8th working
day of the month
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
17
14.3.6
How do you resolve pricing
variances/disputes?
Pricing variances/disputes are to be referred to the internal Risk and Valuations
committee. Significance of the variance is assessed in terms of the fund size and a
decision is made to verify/source a price independently. Pricing needs to be
consistent across all funds for the same securities.
Consultation with the fund manager as well as pricing vendor will take place.
14.3.7 Please describe verification
process:
All inputs of the pricing process are verified to independent third party information.
14.3.8 Please describe the range of
investment strategies you can
value and the process you
follow for each strategy:
We value all investment strategies and follow the same process for each. Trades are
uploaded in the fund valuation system from trade files received and market prices are
uploaded from Bloomberg. Cash, positions, prices, market values & net gains or losses
for a specific period are reconciled to Prime Broker information.
14.3.9 Do you have the ability to price
securities at a particular time,
e.g. ADRs at European market
close, if this is dictated by the
prospectus?
We are able to run at specific times, and at those times pull either Last, Close, Bid,
Offer, Mid or Bid/Offer prices. We will not be able to pull a price at a specific time if
it is not one of the above. Note that this would be manual. We are not in a position to
pull time specific pricing for funds. This is why A&V have to get all Polar Start pricing
manually.
14.3.10 Do you highlight to the fund
board significant holdings in
illiquid stocks?
No
14.3.11
If the fund is a FOHF, please
describe:
1. The process for updating
portfolio valuations,
including the methods for
obtaining prices of
underlying funds,
monitoring receipt of fund
prices on a timely basis,
and the timeliness of the
availability of data to the
FOHF manager:
2. The control processes to
ensure the accuracy of
fund valuations, including
reconciliation and
compliance checks and
verification of estimated
prices against final prices
and audited prices:
1. Underlying fund prices are distributed directly to Market Data who captures same.
Investment certificates & month end statement are collated by the Custody
Department. Copies are made available to the Fund Accounting Department for
completion of the valuations. The Fund Accountants agree the positions in the
accounting system to the custody positions report & also agree month end values to
statements received from the underlying funds administrators. Market Data follows up
on prices (on day 5) & Custody follows up on statements (on day 6) if not received
within agreed timeframes. The Client Relationship Manager continually monitors the
progress & reports to FOHF Managers if there are delays which will impact on agreed
deadlines.
2. The IDS review process involves a Supervisor reviewing each valuation before it is
approved for distribution to the FOHF Manager. IDS will only use estimates if there is a
delay in receiving a final price.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
18
15 RECONCILIATION 15.1 Please describe the process
for, and frequency of,
reconciling security positions
and cash balances for the fund
with:
1. The Manager:
2. The Prime Broker:
3. The Payment Bank:
4. The Custodian (if any):
IDS reconcile positions and cash on a daily, weekly or at least a monthly basis,
dependent on the frequency of NAVs delivered to the client. IDS reconcile the
positions and cash per the administration system (Paxus) to the reporting from the
Prime Broker. IDS do not currently perform three way reconciliations between the
client, Prime Broker, and administrator.
Exception based results are investigated and escalated to the Prime Broker and / or
the client.
Cash balances are reconciled and confirmed to the bank statements/ Prime Broker on
a daily, weekly or at least a bi-monthly basis and reconciling items are investigated
for validity and followed up for resolution immediately.
15.2 Please describe the procedures
for resolving any variances or
differences in such
reconciliations, including
procedures for documenting
such variances and specify who
is responsible for such
documentation:
When a reconciliation results in a variance with the prime broker, the fund
administrator (FA) would fully document it, ensure that all information received is
entered in the accounting system and then elevate the matter to the broker. Where
differences persist the FA will check the client’s trade instructions to the broker’s
trade and settle date activity. All differences will be reported to the broker and IM to
clarify if all details are correct. If changes are required all hard copy will be
requested.
16 FRONT OR MIDDLE OFFICE SERVICES 16.1 Do you provide front and/or
middle office servicing to
managers?
Yes
16.2 If so, please attach detailed
description of such services on
a separate sheet.
Please see attached annexure A
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
19
17 FUND ACCOUNTING SYSTEM 17.1
Please provide Operating
Procedures Manual (describing
how the system(s) work):
This is encapsulated in the “help” facility of the application.
17.2 Please give details of the
accounting/portfolio system(s)
used by the administrator,
including whether system is
proprietary or commercial:
The main accounting system is PFS-Paxus, a fully integrated solution for fund
administration, integrating into one system all the processes that often are performed
on multiple, disparate systems.
The securities module supports various types of trades. The system generates and
posts accounting entries to the general ledger for realised gain/loss, commission
and other charges. Booking of CFDs, futures and options are supported.
Data upload formats are supported from a range of sources.
Complex multi-tiered and pooling structures are catered for.
Supports multiple accounting methodologies (e.g multi- currency, FIFO)
The flexibility of the system allows for a wide range of different and complex fee
structures to be defined and applied. This includes the functionality of defining
multiple fee structures within a fund and for individual classes.
The system contains a powerful multi-currency general ledger module, which is
used as the source for financial statements and fee calculations. The fund’s
balance sheet is thus tied to its assets and performance based fees.
In excess of 30 standard reports are provided, which can be saved in various formats.
Custom reports and statements can be developed as required.
Refer to http://www.pacificfundsystems.com/ for further information.
17.3 Is the administration fully
integrated or are there
separate modules/systems for:
1. Shareholder Services?
2. Securities transactions?
3. General fee calculation?
4. Incentive fee calculation?
5. Others?
1. PFS-Paxus caters for a fully integrated relationship between valuations and investor
servicing.
2. Securities transactions are processed within PFS-Paxus.
3. Fee calculations are automated in most cases, although complex methodologies are
manually captured.
17.4 By who are the systems
maintained?
Systems are maintained by both external suppliers and internal IDS IT and system
specialists.
17.5 Do you have any in-house
capability or do you rely totally
on suppliers?
We have in-house IT support and business support as well as external supplier support for enhanced product capability
17.6 Do the system(s) have
electronic interfaces with
prime brokers and banks?
Yes. We have interfaces with the main Prime Brokers and Banks and can establish links with any new provider.
17.7 If yes, please name the prime
brokers and banks with whom
you currently have direct
electronic access:
Deutsche Bank, Peregrine, Investec, Cadiz, RMB, etc.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
20
17.8 Please name prime brokers
and/or banks with whom you
anticipate having direct
electronic access within 6
months:
We can establish direct electronic access to any Prime Broker or Bank within a few
days.
17.9 How often and when were last
upgrades made to the
hardware used by the
administrator?
Infrastructure upgrades are made as and when needed. Refer to section 24.9
17.10 What procedures are in place
to limit access to fund data to
authorised persons, on a need-
to-know basis?
Each employee at IDS is assigned an individual logon and password. This logon is then
linked to areas on the server which the user will require access to. No user may access
any area of the server/system which they are not authorised to.
17.11 What anti-viral/firewall
procedures do you maintain?
Refer to section 24.11.
17.12 How often are your anti-viral
systems updated?
Refer to section 24.12
17.13 Have you suffered any delays
or disruptions as a result of a
virus getting into your system?
Refer to section 24.13
17.14 If so, please describe when and
in what circumstances:
N/a.
17.15 What is the total annual
budget (as a percentage of
total operating budget) for IT
systems?
Not disclosed.
18 REPORTING 18.1
Please describe reporting
processes available to
managers and investors:
Investor receives a monthly investment statement in PDF format that is emailed
directly from the administration system.
Managers receive batch reports in various formats (Xcel, PDF etc.)
18.2 Can you provide internet/web
accessed reports or full
accounting process to
managers?
Yes, web access is planned for 2011
18.3 Can you provide restricted
internet/web accessed reports
to investors?
Not at this stage. Planned for the future.
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
21
18.4 If “yes” to the previous two
questions, describe password
protection and other
protection procedures used to
ensure confidentiality:
N/a
18.5 Are you able to provide
customised reports to
managers?
Yes
18.6 Describe risk management
reports/analysis tools available
to managers/investors and
method and regularity of
provision of such reports:
N/a
19 FUND SYSTEMS AUDITS 19.1
Have your system(s) been
reviewed by an independent
audit in accordance with ISAE
3402 or another internationally
recognised standard?
Yes, our external auditors signed off an ISAE 3402 type I report in December 2012
19.2
If ISAE 3402 is it level 1 or 2?
Currently IDS holds a ISAE 3402, Type I.
19.3 Was the report qualified or
unqualified?
Unqualified
19.4 Who was the audit firm?
PWC
19.5 Have you changed audit firm?
If so, why?
No, but see 6.6 above.
19.6 Have the auditors of any funds
that you administer ever
required a NAV to be changed
during the administrator’s
term of contract? Please
explain.
No
19.7 Have any of the audits of the
funds that you administer ever
been qualified or reserved due
to an action by your firm?
Please describe the
circumstances:
No
19.8 What comments, if any, have
any fund’s auditors made with
respect to the administrator’s
internal controls?
We have thorough and effective internal controls
20 LEGAL AND TAX 20.1
Please explain your procedures
for tracking:
a) The number of investors
who are US Persons, and;
b) The number of investors
which are of ERISA plans
N/a
N/a
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
22
and US tax-exempt
investors as well as their
non-US equivalents:
20.2 Please confirm that you are
able:
a) To perform PFIC reporting,
and;
b) To provide K1s to US
taxable investors:
N/a
N/a
20.3 What procedures do you follow
with regard to compliance with
the US QI rules?
N/a
20.4 What procedures do you follow
with regard to compliance with
the EU Savings Directive? Are
you the final payment agent?
i) Do you maintain separate
data on EU individual
investors?
ii) Do you monitor the
portfolio of the fund to
determine if it is exempt
from reporting?
N/a
20.5 Are you performing client
identification procedures as
required?
N/a
20.6 Has this impacted on any
existing reporting under
section 17 or 18?
N/a
20.7 Please confirm that your
standard administration
agreement does not provide
for your liability to be capped:
N/a
20.8 Please provide a sample of
your standard agreement:
To be provided on request.
21 CORPORATE SECRETARIAL AND DIRECTORS SERVICES 21.1
Do you provide corporate
secretarial services?
Yes- Separately charged at tariffs set by SAICA
21.2 If so, please describe:
We offer comprehensive secretarial services and should the fund require, we can
attend to those as and when required.
21.3 Do you provide directors? No
21.4 If so, corporate or individual
directors?
N/a
21.5 Do you impose any restrictions
on directors’ involvement in
management of the fund?
N/a
21.6 If so, please describe: N/a
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
23
21.7 Are you prepared to take
responsibility for informing the
board in good time of all
regulatory filings that are due
and if so in which jurisdictions?
N/a
22 FEES 22.1 On what basis do you charge
your fees for:
Administration?
Registrar & Transfer
Agency?
Corporate Secretarial?
Directors?
Others?
for a fund with the following
characteristics (to be
completed by manager):
Estimated size at launch:
No. of valuations p.a.:
No. of Dealing Days p.a.:
No. of Shareholders:
Volume of Security
Transactions:
Any special features or
esoteric investments:
Listed OTC instruments.
This section is subject to a separate and valid Non-Disclosure Agreement
N/a
N/a
N/a
N/a
N/a
N/a
N/a
23 OPERATIONAL RISK 23.1
How does the company define
operational risk?
The risk of loss arising from human error, management failure and fraud, or from
shortcomings in systems or controls.
23.2 Does the company have an
operational risk management
framework? Does the
framework consider how the
company identifies, assesses,
monitors and controls
operational risks?
Yes
Yes
23.3 Are the employees responsible
for the operational risk
framework adequately
independent from the business
and appropriately trained?
(For example, does the
company have a risk or internal
audit function that is
responsible for the
framework?)
Yes
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
24
23.4 Does the board of directors
approve and regularly review
the operational risk
management framework?
Yes, via the Audit Committee
23.5 Who is responsible for
implementing the operational
risk framework? Are there
clear lines of responsibility
across senior management?
Risk and Compliance Manager, Liza Fourie (Cape Town)
Yes, in terms of functional responsibilities.
23.6 How does the company ensure
that employees understand
their responsibilities for
implementing the operational
risk framework?
Through line management training and review.
23.7 What on-going assurance does
the firm provide to clients over
the effectiveness of its
operational risk framework? If
a SAS70 or FRAG 21 (being
replaced by AAF 01/06) has
been completed? Please list
the key weaknesses identified
in the last 5 years.
Please see 19.1 & 19.2
24 BUSINESS CONTINUITY/DISASTER RECOVERY 24.1
Please describe your disaster
recovery (business continuity
management- BCM) plan:
The current BCM plan is based on a program of regular backups and an alternate work recovery site on a different electricity grid. The plan is reviewed by-annual in order to keep it current and up to date
24.2 Do you have a dedicated BCM
Manager overseeing your plan?
Riana Hoefer
021-4021600
24.3
Do you have a back-up
recovery site? If yes, where is
it located and is it a dedicated
or shared facility?
TCM premises in Canal Walk. TCM is a shared facility and has subsidiary
offices in Johannesburg and Durban, which are also available to us should
there be a need. Refer to www.tcm.co.za for further information.
24.4
How long should it take to be
operational, if existing
premises were out of action?
Should we have the need we could be up and fully operations at our
proposed site within 24-48 hours.
24.5
Has the recovery site been
tested? If so, when was the
last test? Please provide a
copy of the latest report.
Yes, the last test was conducted in November 2013
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
25
24.6
Do you back-up data on
systems regularly? If so, how
often? Is this back-up a
manual or automated process?
All backups are automated, and all system state data are backed-up daily.
Separate backups are also made twice daily to a separate backup server
onsite, which is mirrored to an offsite backup server every evening.
24.7 Are back-ups stored onsite or
offsite? If offsite, where?
Backups are stored onsite, and we have a mirrored backup server housed in
the secure facility at Internet Solutions in Cape Town.
24.8 Do you create back-up copies
of physical documents?
No.
24.9
How often and when were last
upgrades made to the
hardware used by the
administrator?
Upgrades are made as and when needed. All servers were virtualised and
upgraded in 2013.
24.10
What procedures are in place
to limit access to fund data to
authorised persons on a need-
to-know basis?
Each employee at IDS is assigned an individual Logon and Password. This
logon is then linked to areas on the server which the user will require access
to. No user may access any area which they are not authorised to.
24.11
What anti-viral/firewall
procedures do you maintain?
All Computers connected to our network run Sophos AntiVirus software. This
software is updated every hour from the internet with updated Virus
definitions and protection. All computers run on-access scanning, which
means that anytime a file is accessed it is scanned for threats first. All
computers also run a full HDD scan once a day. We use Sophos Proxy and
Fortinet firewalls on our Internet Lines. No user is able to connect any kind of
disk (CD, Flash drive) to their computers as it is blocked.
24.12 How often are your anti-viral
systems updated?
The Virus Definitions are downloaded and updated every hour. The
Application version is updated whenever a new release becomes available
24.13
Have you suffered any delays
or disruptions as a result of a
virus getting into your system?
Not in past 36 months.
24.14 If so, please describe when and
circumstances:
n/a
24.15
Have procedures been subject
to an external review and if so
by whom?
All of this has been thoroughly revised as part of ISAE 3402 – See 19.1&19.2
25 GENERAL – STAFF
The information given herein is correct as at: 31 December 2013
This questionnaire is based on AIMA’s Illustrative Questionnaire for the Due Diligence for Hedge Fund Administration
for Managers (2007)
26
25.1
What procedures are in place
to maintain staff
confidentiality of investor
information?
All staff is aware that they are obliged to maintain investor information
confidentiality as a condition of employment with the IDS Group and breach
of this condition may result in dismissal. In addition to the IDS employment
conditions, all staff are trained in aspects of hedge fund administration and
procedures and are aware of the consequences of breach.
25.2 Do you provide written job
descriptions to staff,
particularly with regard to
specifying responsibilities and
duties of fund administration
and shareholder services
functions?
All job functions have written job descriptions which include details of
minimum levels of education and experience
25.3 Do you impose minimum
experience and educational
standards for each position?
As noted above, all job functions require minimum levels of education and
experience
25.4 Do you offer any training to
maintain and improve
education levels for staff?
Training is available to all members of staff. This may take the form of in-house or external training.
This Due Diligence Questionnaire has been prepared by:
Signature:
Name: Tony Christien
Position: Director, IDS Group
Date: 30 January 2014