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When an allocator calls: Best Practices for a CTA’s back office

  • By Dana Comolli, president, DMAXX LLC

Every trader who has tried to raise money knows the drill from investors: yes we want to know about your performance, but also, explain in detail your back office (infrastructure, organization). Most allocators come with pages of checklists and expect the manager to be able to answer their questions in full.  What do allocators expect and what does it really means to have a back office that passes investment standards?

Allocators like stability and thoughtful, business-like leadership that goes beyond what the yen will do tomorrow. Obviously, a core aspect of their job is performing due diligence on potential (and current) managers to make sure CTAs live up to these expectations. Many have a separate unit that only performs operational due diligence, and if they find anything amiss, even if the trader has outstanding performance, the investment will get nixed.  As Joe Vanderbosch of Dominion Capital Management notes: Allocators are looking for reasons to stop looking at you. So here some first hurdles allocators want an asset manager to overcome as well as a checklist of essential back office needs and how to prepare.

  • Performance metrics: It’s not enough to have good performance, you need to be able to get into the granularity of it with daily and monthly performance data including information such as P&L attribution by market and sector, volatility, VAR and standard deviation. Vanderbosch notes that your end-of-month performance might be up 2%, but an allocator wants to see within those numbers and hear you explain them in an organized and disciplined fashion.
  • Reinvestment: Are you regularly investing in research and systems? You’ll have to show how you update not only your trading systems, but prove that you’re properly funding the research team and operational infrastructure.
  • Personnel: Obviously if a key manager leaves, the question is why? How was that person replaced? How long has personnel been with the firm? Who makes up the trading desk? Who runs the back office? What is the turnover rate? These answers need to be explained thoroughly, especially if there was a personality rift between principals and key managers/traders.
  • Expenses: Where is the money being spent, especially related to fees? Extravagance is a turn off.
  • Transparency: Holding back information when explaining your systems won’t win points. Allocators often feel CTAs think they’ve discovered the Holy Grail when it’s a simple trend following program. One London consultant noted a coy trader wouldn’t be recommended to clients.
  • Execution: Allocators realize this is a main ingredient in the trade process and expect CTAs to understand its importance and be able to explain it fully during due diligence. They want to see that you have a detailed process that is transferable across your team.
  • Outside advice: The make up of your board should have at least one Independent director, an independent fund administrator and solid outside service providers. Unknown, poor quality service providers can show a lack of commitment to invest in the business.

So what does that mean to the trading manager?

Mike Dever, CEO and Director of Research of Brandywine Asset Management, has been a CTA since the 1980s and has gone through many allocator reviews – and received many investments. He says typically the allocator will send an itinerary of what they want to review and if they don’t, Mike will ask for one. Also, more common today there are two groups that come from the allocator: one that comes in to discuss philosophy, research and strategies with the manager/traders, and the second is operational, charged with determining how the CTA executes trades, what’s its relationship to its brokers, and what is the underlying technology; basically the back office details.

To prepare, Dever and his team put together all the requested information, data print outs and examples, in one large notebook that they’ll review with the allocator when they visit. They also will go through the actual back office process, for example, providing a demo account, allowing the allocator to sit in and experience the process step-by-step.  He says his team does practice drills before an allocator review to make sure the meeting runs smoothly.

So let’s discuss these best practices and what they mean to the CTA:

  • What is your general setup: legal structure, ownership breakdown and financial strength? But beyond that they want to know about key personnel and with that, segregation of duties (ie. compliance can’t be sales, operations shouldn’t be accounting). Some back office accounting software, like TheBooks, has the ability to limit access to certain parts of the business via security codes, and can be defined by personnel or job function.

Also scrutinized will be cross training of personnel; if someone is sick that day or an emergency arises, can others step in and provide the same quality of service? Do you have a process set up for new hires? And what happens when you travel? What is your back up, both for that day as well as the bigger picture in transacting business?

  • Who are your key service providers? These include back office accounting software, general accountants, FCMs, technology providers, administrators and even temp agencies. You’ll need to outline how these firms are chosen, what roles they fulfill and on what basis are they are dismissed. Here allocators look for depth: they want to make sure the CTA is buying the provider not just for pricing, but because it actually does what is needed. Also, how do you monitor vendors? For example, do you or someone else at the firm review end-of-day results, and if not, they should be. Allocators will want to see a checklist.

Annette Cazenave, principal of A. Cazenave LLC, says: “Let’s face it, your two big areas of liability are striking NAV and how you sell [your products], so you need to review everything before you push it out the door.” Also, if you lose a key person, can your service providers step in to fulfill that need until you’ve gotten the next person up to speed? Do you have that action plan set up?

  • Operational processes and procedures for trading controls, compliance, valuation and treasury. This includes being able to show reproducibility of trades, daily trade files, valuation checks and transparency. It also means showing how you move the money around as well as how you handle new allocations.

Dever says they typically need to document a trade: how was it generated, how did it get sized, how was it allocated per client and why, who was involved in trade? Again, having reliable back office software that can document trades is key. Todd Fulton, senior VP, capital introduction, for R.J. O’Brien, advocates all traders have back office software, noting, “Trade checking is a major part of what I like about TheBooks.” Alan Zenk, who runs CTA Services, a service bureau for smaller CTAs, says that the NFA recently has focused on trade allocations and making sure they are handled similarly across all accounts. With various sized managed accounts, this could be a nightmare for CTAs and a major trip up in a due diligence review.

  • IT infrastructure, cyber security and disaster recovery: You’ll need to outline the IT infrastructure of the company, explain your account security and what happens if an event, man-made or not, brings the system down. This doesn’t mean necessarily a 9/11, but could mean the Internet going down, an electricity grid failure, or a snowstorm (or other natural disaster). For example, if a huge storm is coming, are you getting hotel rooms for key personnel? The answer may be yes, but what’s your game plan? Remember too, third party vendors are helpful in this situation as they can serve as back ups and remote offices: know ahead of time what you can rely on and be able to explain it. This certainly is a mark of a prepared trader who is ready to take on large allocations.

It’s a formidable task to be a successful hedge fund or CTA, but actually designing a winning model and/or strategy is only one part of the success quotient. Making sure your back office is well structured is key, and though standards may differ allocator to allocator, the points highlighted here are a minimum.  Think of it like this: trading is driving the race car, but it’s the pit crew that wins you the race.


Dana M. Comolli is president of DMAXX (, a back office software design firm for alternative investment managers. TheBooks software is designed for the trader, and is built to do price, position and order management, reconciliation, trade accounting, performance reporting, risk and data management and act as a gateway to a wide variety of execution platforms. You can reach Dana at: