What Compliance Records Should a Manager Be Willing to Provide?

A manager should be able to show records that connect its written compliance policies to assigned duties, actual reviews, and follow-up on issues. You are looking for a clear account of what records exist, who keeps them, and how the manager checks that required work was completed.

Ask for a Records Inventory

Request an index of the compliance records the manager maintains, with the record owner, retention period, and format. The inventory may cover the compliance manual, policy acknowledgements, training logs, review calendars, exception logs, complaint records, and documentation of periodic policy updates. Ask for the date of the last review and who approved it.

Request the policies that relate to the fund's operations, or a suitable summary if the full manual contains sensitive material. Ask how the manager documents conflicts, personal transactions, marketing review, communications retention, and employee access to fund information where those subjects apply. The manager should explain which policies apply to each role and how new staff learn them.

Look for Records of Work Performed

A policy on paper does not show that anyone followed it. Ask for a redacted sample of a completed review, an exception log with confidential details removed, or a walkthrough of a recent control cycle. Useful evidence can include a dated checklist, reviewer sign-off, issue assignment, resolution note, and confirmation that corrective steps were completed.

Ask who reviews the records and whether the reviewer is separate from the person who performed the underlying task. If an administrator, bank, or outside compliance provider holds a record, find out what the manager receives, what it reviews, and how it follows up on a missing item. Outsourcing a task does not by itself show that the manager oversees the result. Compare the records with the manager's broader disclosures and its description of its compliance program.

Handle Limits and Gaps Directly

Some files may contain personal information, privileged communications, or details about other investors. Ask whether the manager can provide a redacted copy, a summary, or a supervised review under confidentiality terms. A restricted file may have a reasonable explanation, but the manager should identify the limitation and offer another way to assess the control.

Ask focused questions:

• "Who owns the compliance record inventory, and when was it last updated?"
• "Can you show a redacted example of an exception from identification through resolution?"
• "Which records are held by an outside provider, and what do you review?"
• "What material control issue remains open, and who is responsible for closing it?"

Vague answers, records with no dates or reviewer, and repeated gaps between policy and evidence deserve follow-up. Keep a log of requested items, what you received, and any limits the manager described. Do not treat a missing sample alone as proof of misconduct. Ask for a specific substitute and a written explanation. For related checks, review signs of weak financial controls and how to handle disclosure gaps. Have your attorney or a compliance specialist assess which records fit this fund and the rules that apply.

Checklist

• Get a dated inventory of compliance records and record owners.
• Review relevant policies, acknowledgements, and training logs.
• Request redacted evidence of completed reviews and resolved exceptions.
• Identify records held by service providers and the manager's oversight steps.
• Document unavailable items, explanations, and substitute evidence.
• Refer jurisdiction-specific questions to counsel or a compliance specialist.

Go deeper: How should a family office review a fund's anti-money-laundering procedures?.

For a variety of reasons, full access to past and current records should be strictly limited, and those restrictions should be documented in your governance documentation.

Sources: The Family Office Book, The Single Family Office. Informational only, not financial, legal or tax advice.