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RFG's 2019 Annual Survey Questions

Background Information

The information provided in this section will help us better interpret survey responses.

1. What is the AUM of the endowment funds you advise?

Less than $1 billion

Between $1 billion and $3 billion

Between $3 billion and $5 billion

Over $5 billion

2. What percentage of the endowment AUM is invested in...

Commingled marketable funds (long only funds, hedge funds, mutual funds, etc):

Commingled non- marketable funds (private equity, private credit, private real estate, etc):

Directly held investments and separately managed accounts:

Other (please describe):

3. Do you advise other funds, such as operating funds?

No

Yes (please describe the type of fund(s) and their AUM):

Investment Office Staffing

For each of the following functions please indicate the number of staff servicing the function that are sourced from the investment office, the endowed organization, or whether the function is outsourced to a third party. (If a person works within the investment office, that person counts as investment office staff—even if employed by the endowed organization.) If a function is outsourced, simply check “outsourced” by providing a brief description of the provider—there is no need to provide a staffing number. Please focus on the number of staff and not whether the person devotes full time to the function. For functions serviced by multiple providers, please provide more detail on how responsibilities are assigned.

Please enter both the number of staff and the specific responsibility details (i.e. "3; managing investments")

4. Investment personnel number and responsibilities:

Investment office:

Endowed organization:

Outsourced:

5. Operations personnel number and responsibilities:

Investment office:

Endowed organization:

Outsourced:

6. Finance personnel number and responsibilities:

Investment office:

Endowed organization:

Outsourced:

7. Legal personnel number and responsibilities:

Investment office:

Endowed organization:

Outsourced:

8. Compliance personnel number and responsibilities:

Investment office:

Endowed organization:

Outsourced:

9. Internal audit personnel number and responsibilities:

Investment office:

Endowed organization:

10. ODD Function number and responsibilities:

All investment office staff that participate in ODD:

Investment office ODD- dedicated staff:

Endowed organization:

Outsourced:

11. Who in-house has primary responsibility for your ODD Function (eg. COO, investment team etc.)?

12. Which investment office staff areas participate in the ODD process (please check all that apply)?

Investment

Operations

Legal/Compliance

Other (please specify):

13. Between the investment office staff and outside consultants, as measured by the number of investments, what is the percentage ratio of the workload split? (i.e. 50% investment office, 50% outside consultants)

14. How does your organization handle risk metrics?

We rely solely on products offered by our global custodian

Other (please describe):

15. What is the majority source of the returns shown to your Investment Committee?

Custodian calculation

In-house controllers calculation

External administrator calculation

Other (please describe):

16. How frequently do you reconcile fund valuation with fund managers?

Quarterly

Monthly
More frequently than monthly or other (please explain):

17. Do you use a valuation agent other than your custodian? Please indicate who and why:

Board and Investment Committee Issues

The role played by the board and other governing bodies has come under increased focus in the past year and is likely to be subject to further scrutiny in the near future.

18. Investment discretion resides with what entities?

CIO can act alone

CIO sources but needs IC approval OCIO can act alone
OCIO sources but needs IC approval IC mostly acts alone

Other (please explain):

19. When a new member joins the investment committee or governing body, the following steps are taken (please check all that apply):

A background check is conducted

They are expected to provide substantive initial conflicts disclosures

They are expected to provide substantive ongoing conflicts disclosures on a periodic basis

We have a policy requiring recusal if an item being discussed involves a potential conflict on the part of a member

We have a policy prohibiting investment if the member is associated with a potential investment (e.g., the member is a manager in a fund we might otherwise make an allocation to)

We provide training on our organization
We provide training on the legal and regulatory environment in which we operate

We provide training on investment office compliance expectations

Please note anything else you would like to mention here:

20. Trustee conflicts of interest: Forgetting past investments and only looking forward, does your institution allow investments where the associated fees will flow into a Trustee's or IC member's pockets?

Hard no
Yes with little to no restriction
Yes but only if fees are deemed immaterial, and materiality is defined
Yes but only if fees are deemed immaterial, and materiality is not defined
Yes but there are so many approvals required (Audit Committee, Full Board Approval, etc) that it is essentially a ban

Other (please explain):

Compliance Program

The DOJ and OFAC have just updated guidance on the type of compliance program they will expect from all U.S. legal entities. This section provides a high-level indication as to whether your organization is in line with the newly-articulated standards.

DOJ Expectations (please select "yes" or "no" for the following areas and provide additional details):

21. We have a compliance risk assessment for all Federal laws which has been reviewed at least once in the past year.

Yes, we meet

No, we do not meet
Other comments? Is it reviewed more than once a year?

22. We have a compliance manual that is tailored to the needs and activities of the investment office.

Yes, we meet

No, we do not meet
Other comments? How often is it updated?

23. We conduct periodic training on the compliance program and high-risk areas.

Yes, we meet

No, we do not meet
Other comments? How frequently do you train? Who does the training?

24. We periodically test the adequacy of our compliance program.

Yes, we meet

No, we do not meet
Other comments? What tests do you undertake?

25. We provide senior governing entities with reports on our compliance program.

Yes, we meet

No, we do not meet

Please describe what is done:

26. When we purchase a significant stake in a fund or company, we review the adequacy of its compliance program.

Yes, we meet

No, we do not meet

Please describe what is done:

27. Do you require annual policy attestations from employees and members of governing bodies?

Yes to both

Only from employees

No

28. What topics are covered in your compliance program (please check all that apply)?

Personal trading

Insider trading
Market manipulation
Foreign Corrupt Practices Act and anti-bribery

Sanctions programs (OFAC and others)

Whistleblower policies
Antitrust issues
New activity procedures
Conflicts of interest
Confidentiality
Cybersecurity

Data privacy
Gifts and entertainment

29. Does your compliance program utilize software as part of any process?

No

Yes (please describe what software is used):

Trading Restrictions

The nature of your endowment’s trading strategy may be relevant when crafting your trading compliance program. The questions in this section apply only to trading policies, not policies covering other areas.

30. Please check the boxes below that describe your endowment's current trading profile:

No direct trading by the endowment

Ad hoc direct trading and/or investment on a case-by-case basis
Direct trading in limited classes of publicly registered securities
Direct trading/investments in other limited asset classes, which may include private companies

Active management of one (or more) in-house direct strategies
Other (please explain):

31. Do you have a trading policy (please check all that apply)?

No

Yes, and it applies to trades made by the investment office on behalf of the endowment

Yes, and it applies to personal trades made by our investment office staff
Yes, and it applies to personal trades made by our investment committee
We do not have an investment committee

Yes, and it applies to personal trades made by our endowment governing body

32. What types of personal trading does your trading policy prohibit or place limitations on (please check all that apply)?

Investing in the same products/holdings in the institution’s portfolio or pipeline (prospective investments)

Investing in private placements and limited offerings
Front running the institution
Front running a manager

The use of MNPI for personal trades
The use of confidential information obtained in the course of employment for personal benefit

Day trading and/or active trading
Other (please share other areas of note):

33. For any areas checked as covered in Question 32, please describe any applicable carve outs or limitations. For example, we only prohibit active trading within a 30-day window or we only address certain types of private placements:

Questions 34 to 39 ask who is responsible for undertaking tasks required as part of the compliance program’s trading policies:

34. Maintaining restricted list:

We do not do this

Legal
Compliance
Operations
Other (please describe):

35. Approving a request to trade for endowment portfolio:

We do not do this

Legal
Compliance
Operations
Other (please describe):

36. Approving a request to trade for personal portfolio:

We do not do this

Legal
Compliance
Operations
Other (please describe):

37. Reviewing employee trading reports (such as brokerage statements):

We do not do this

Legal
Compliance
Operations
Other (please describe):

38. Conduct training:

We do not do this

Legal
Compliance
Operations
Other (please describe):

39. Testing:
We do not do this

Legal
Compliance
Operations
Other (please describe):

Questions 40 to 43 concern how you manage your restricted list:

40. If you maintain a restricted list, who does it apply to (please check all that apply)?

Investment office personnel

Members of our investment committee

Members of our governing bodies

41. Do you exclude ETFs from the list?

Yes, all ETFs

Yes, but only broadly-based ETFs are excluded (meaning narrowly-based ETFs may be on the list)

No, ETFs are not excluded

42. When do you add a security to the list?

Only when we have MNPI

When compliance deems prior review to be relevant such as to avoid potential front running, comply with a non-disclosure agreement, or where family members are on the board of a public company

Other or another reason to add a security to the list (please explain):

43. When do you remove securities from the list?

Miscellaneous Questions

44. Do you make investments in companies which are active in areas where your endowed organization is also engaged in research?

Yes

No
If yes, please describe any internal restrictions that are in place:

45. Do you allow employees who represent your organization on corporate boards to accept personal compensation, such as equity stakes or stock options, from the companies?

Yes

No
If yes, please describe any internal restrictions that are in place:

Would you be interested in using RFG for the following purposes?

46. As an outsourced compliance officer?

Yes

No

Comments:

47. As outsourced staff to assist existing compliance staff?

Yes

No

Comments:

48. To provide staff training?

Yes

No

Comments:

49. To provide training to the investment committee or other governing body?

Yes

No

Comments:

50. Other areas (please describe):

51. Any suggestions about how to improve RFG's service offerings?

52. Any other suggestions or comments?

53. Thank you for participating. If you are not a member of the RFG consortium, please enter your email address here to receive a copy of the survey results: