Two LPs, one consultant's platform, two different answers

A US middle-market buyout sponsor, roughly $1.8B in assets under management across four funds, with a Cayman feeder and a co-invest program. Eleven platforms, seven add-ons, industrials and business services. The back office is four people: a CFO who is also the chief operating officer, a fund controller, a chief compliance officer who also carries investor relations, and a rotating associate. Fund accounting is outsourced, the CRM is DealCloud, and IT is a part-time managed service provider.

• Twelve institutional investors and four consultants sent questionnaires in six weeks, and two analysts worked the pile by opening the last completed pack and pasting the closest prior answer
• By the fourth pack the valuation governance answer said the investment committee approves marks quarterly, while a version already sent said the CFO prepares them and the committee reviews later
• Neither matched the compliance manual, which described a valuation committee the firm had stopped convening in 2023, and the two investors holding the two versions sit on the same consultant's platform
• An examination letter with a 14-day return date asked for the records supporting every performance figure used in marketing; the CFO rebuilt one correctly but could not prove it was the number that had been printed
• Six of the twelve questionnaires asked for things that exist only inside the operating companies, so an associate emailed 18 portfolio CFOs and got back four formats and two people who had left

We built a compliance and evidence platform around the firm's existing systems, sequenced so the contradictions in the questionnaire pile were resolved first. We did not touch the administrator's ledger, the fund accounting platform, or the investor portal, because those belong to the products that own them.

The answer library

Every response the firm had given became a record rather than a paragraph in a file: canonical answer text, the question variants it satisfies, a named owner, an approval date, a review interval, and attached evidence. Roughly 240 answers survived deduplication of over 700 near-identical fragments, and the losing version was kept as superseded rather than deleted, because an investor already had it.

Document processing over source evidence

The compliance manual, the provider's controls report, prior regulatory filings, the code of ethics, the valuation policy, and vendor contracts were parsed, sectioned, and mapped to the questions each substantiates. Evidence stopped being a folder and became a link, and when a controls report is reissued the system surfaces the answers whose evidence just changed.

First-draft assembly with a reviewer gate

An incoming questionnaire is matched question by question against the library, matches are drafted, and unmatched questions become library candidates once someone answers them. Nothing goes out unreviewed: the reviewer sees the proposed answer, its owner, its approval date, and its evidence beside the question as the investor worded it.

Performance substantiation register

Every performance figure used in marketing carries a record: the calculation, its inputs archived at the time of use, the methodology note, the approver, and each document the figure appears in. Change a figure and the register lists every document in market that must be re-papered.

Portfolio-company evidence pipeline

The same document layer was pointed at the 18 operating companies. Insurance certificates, audit reports, safety logs, and material customer contracts are collected once per entity and read for the fields that get asked about: carrier, coverage limit and expiry; report period and scope; change-of-control, assignment, and data-protection clauses. Change of control matters most, because it surfaces again at exit.

Filing calendar with evidence captured at the event

Each regulatory filing element maps to a source and an owner, with the supporting artifact captured when the event happens rather than the week before an examiner asks. The calendar tracks moving ground as well as fixed dates, including requirements whose compliance dates have shifted more than once.