Recommended position
Export DD memo (PDF)
Send to ManCo / fund admin (stub)
Accept / override flags
Audit drawer (on click): Source = fund DDQ / custody confirms — no independent qualified custodian; assets held in the manager's own name; NAV self-reported (no third-party administrator); auditor a two-partner affiliate. The Madoff question: who actually holds the assets? Recommendation: DO NOT PROCEED until independent custody, third-party-struck NAV, a recognised auditor and clean re-executed subscription docs are in place.
13O/13U note: had the family committed S$22M and carried it at the manager's mark, that unverifiable value would have inflated its qualifying AUM and put its 13O/13U incentive at risk (failed-condition / clawback). The same catch protects the capital and the tax status. Decision support — not tax advice.
Pipeline trend — this family office
S$140M
proposed commitments screened YTD · 4 of 11 managers flagged on operational controls (custody / NAV / audit). ~85% of LPs reject a manager on operational concerns alone.
Bars = $ screened per month · amber = a manager flagged on operational controls.
Anchor — Madoff: IDD said the returns were real; ODD asks who holds the assets. JES Capital: ~US$95M of forged subscription signatures. The same two patterns, caught here before commitment.