Insights · Practice

What "document your process" means in an examination

13 September 2026 · 1 min read · Marnello LLC, produced under the direction of the Manager (Jingchang Song)

The request usually arrives as a list: for a sample of accounts, show the basis for the allocation, when it was decided, what information was considered, and who reviewed it. Firms with a policy manual and a good story tend to be surprised by how little of that counts. Policies describe what should happen; the examiner wants evidence of what did.

Quantitative evidence answers a narrow part of that request, but it is the part small firms most often cannot produce internally: a dated measurement of what the portfolio's characteristics actually were, with the method written down. A factor exposure report from the quarter in question, with its methodology appendix and a reviewer's sign-off, is a contemporaneous record. A spreadsheet built the week before the examination is not.

The same logic applies to marketing. A claim that the firm "applies a disciplined factor framework" is a statement of material fact in an advertisement; under Rule 206(4)-1(a)(1) the adviser must have a reasonable basis for believing it can substantiate the statement upon demand, and Rule 204-2(a)(16) requires the records supporting performance claims to be kept. A dated measurement with the method attached is evidence for the loading it measures; it does not by itself prove that a process was followed. This is the reason Marnello's products are built around documentation first and analysis second, and why Core, Professional and Enterprise deliverables carry a governance record on their last page. We are not a compliance service and this is not legal advice.

Insights are general research and commentary. They describe method and practice; they are not legal or compliance advice and not tailored to any firm. Standard disclosure applies.

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