Skip to content

For professional and eligible investors. Capital at risk. Product-specific materials are access controlled.

Block Asset Management
All insights
Manager Selection

What ends a manager review, and what only looks like it should

A due diligence process that never says no is not a process. This note sets out what genuinely ends a manager review, why most of it is about response rather than fact, and the characteristics that look disqualifying to an inexperienced reviewer and are not.

21 August 202610 min read
  • Very little is disqualifying on its own. What ends a review is usually a pattern, or the way a manager responds when a gap is put to them.
  • A small number of structural conditions are genuinely terminal, because they remove the possibility of verification rather than merely raising a question.
  • The most reliable signal is not the answer to a hard question but what happens after it: whether the promised document arrives, and whether the second answer matches the first.
  • Several characteristics that look alarming — a small team, an unfamiliar structure, a poor year — are not disqualifying, and treating them as such removes good managers for bad reasons.
  • A rejection has to be recordable in a sentence. If the reason cannot be written down, it was probably discomfort rather than a finding.

Almost nothing disqualifies on its own

Reviewers new to the work tend to look for a single decisive fact — the one disclosure that settles the question. It is rarely available. Most individual findings have a reasonable explanation, and a manager with a reasonable explanation for each of ten findings may still be one nobody should allocate to.

What ends a credible review is usually one of two things: a pattern that persists across otherwise unrelated areas, or the manner in which a manager responds once a gap has been put to them plainly. Neither is a fact discovered in a document. Both emerge from the process of asking.

The conditions that are genuinely terminal

A short list of conditions ends a review not because they are alarming but because they make verification impossible. Everything else in a diligence process depends on the ability to check something against an independent source; where that ability does not exist, no amount of further work improves the position.

  • No independent valuation — where the manager both runs the strategy and determines what it is worth, with no independent administrator or pricing source, there is nothing to reconcile an assertion against.
  • No meaningful segregation — where client assets cannot be distinguished from the manager's own, in any sense that would survive an insolvency.
  • An unauditable position — where no auditor will express an opinion, or the entity has never been audited and cannot explain why.
  • A regulatory position that does not permit the activity — where what the entity is authorised to do and what it is actually doing do not correspond.
  • Unwillingness to be examined — where basic operational questions are refused rather than answered imperfectly, and the refusal is the answer.

The response matters more than the finding

The most informative moment in a review is usually not the discovery of a gap. It is the twenty minutes after the gap is raised.

A manager who says a control does not exist, explains why, and describes what compensates for it has given a reviewer something to assess. A manager who produces an immediate, comprehensive answer that does not quite match the documentation has given the reviewer something rather different. So has one who agrees to send a document and does not.

None of these is proof of anything. But they are observable, they repeat, and they are considerably harder to manage than a written answer to a written question — which is precisely why they carry information that a questionnaire does not.

Patterns worth taking seriously

A pattern is worth more than any of its parts. These are the ones that tend to matter, each unremarkable in isolation.

  • Documents that disagree with each other — where the offering documentation, the marketing material and the answers given describe subtly different arrangements.
  • A history of provider changes without explanation — auditors, administrators or custodians replaced repeatedly, with no account of why.
  • Answers that improve on retelling — where a second conversation produces a materially more satisfactory version of the first.
  • Everything depending on one person — not merely key-person risk, but a firm where one individual is the only source of every answer.
  • Consistent deferral — where the substantive material is always about to be provided, and the process advances on assurance instead.

What looks disqualifying and is not

An inexperienced review removes good managers as readily as bad ones, and usually for reasons that feel prudent. These are the characteristics most often mistaken for findings.

A small team is not a finding. Many capable managers are small, and the relevant question is whether responsibilities are separated appropriately for the size, not whether the firm has a department for each function.

An unfamiliar structure is not a finding. It is a reason to establish what the structure does and under which law, and unfamiliarity to the reviewer is not a defect in the manager.

A poor period is not a finding. A strategy that behaved as described in a difficult environment may be more informative than one that did not have to.

Nor is a candid disclosure. Managers who volunteer their weaknesses tend to be assessed more harshly than those who do not have any to disclose, which rewards exactly the wrong behaviour and should be resisted deliberately.

A rejection has to be writable

The discipline that keeps a process honest in both directions is the requirement to record the reason in a sentence someone else could read.

If the reason can be stated — the valuation is not independent, the regulatory permissions do not cover the activity, three documents describe three arrangements — it is a finding, and it will still make sense in a year. If it cannot be stated without reaching for impressions, the review has produced discomfort rather than evidence, and discomfort is not a basis for a decision that would be defended to an investment committee.

That requirement cuts both ways, which is the point of it. It stops a manager being rejected on atmosphere, and it stops one being approved because nobody was willing to write down what was wrong.

It is a decision about a process, not about people

A conclusion that a manager is not suitable for an allocation is a statement about verifiability, structure and fit — not a judgement about competence or integrity, and not a claim that anyone has done anything wrong.

Keeping that distinction is more than good manners. A review conducted as though it were searching for wrongdoing produces defensiveness, and defensiveness produces worse information. The most productive reviews are the ones where a manager understands that the reviewer is trying to establish what is true rather than to catch them out — and those reviews surface more, not less.

How Block Asset Management helps

Our manager research and operational due diligence exist to establish what can be verified and to record what cannot. What we conclude about any particular manager is confidential, and saying so plainly is part of what makes the process credible.

Assessment against defined areas

Managers are assessed across the eleven areas of our operational due diligence and on investment process, risk discipline, infrastructure and the durability of their edge.

Verification sought before assurance is accepted

We look for documentation, independent attestation and observable controls, and record where an answer rests on the manager's word alone.

Those who research do not approve

Research and recommendation sit with Investment & Research; approval sits with the investment committee of the relevant structure. The separation is real.

Findings recorded rather than resolved by inference

Where something cannot be established, it is recorded as such — which is what allows it to be pursued, or to be weighed openly in a decision.

Assessment continues after allocation

Manager review does not stop at the point of allocation. Continuous supervision is accompanied by a periodic formal re-underwriting review.

Conclusions kept confidential

We publish how the process works and never its results in respect of any manager or structure. The findings belong to the process, not to the marketing.

The purpose of a manager review is not to find a reason to say no. It is to establish what can be verified, to be honest about what cannot, and to make the resulting decision in a way that a colleague could reconstruct a year later from what was written down.

If your organisation is building or revising a manager selection process, our investor relations team can discuss how manager research and operational due diligence are conducted within our own.

Important information

This material is provided for information purposes only and is intended for professional and qualified investors. It is general commentary on manager selection and operational due diligence practice and does not constitute investment, legal, tax or operational advice, nor an offer, solicitation or recommendation of any strategy or financial instrument. It does not describe, refer to or characterise any specific manager, firm or structure, and it does not report any finding reached by Block Asset Management, which are confidential. The characteristics discussed are illustrative of general practice and are not allegations of misconduct by any party. Due diligence reduces but cannot eliminate risk. Digital assets are volatile and involve significant risk, including the possible loss of the entire amount invested. Past performance is not a reliable indicator of future results.

Subscribe to our investor updates

Register your interest to receive future research and commentary.