Building a Resilient Investment Policy in Uncertain Markets

Introduction: The Imperative of Investment Policy Resilience in an Uncertain World

The Evolving Risk Landscape for Institutional Investors

The contemporary investment landscape presents institutional investors, pension funds, endowments, foundations, and sovereign wealth funds, with an increasingly complex and volatile environment. Market shocks, driven by factors ranging from geopolitical crises and pandemics to sudden bursts of volatility and fundamental paradigm shifts, appear with growing frequency and intensity. Recent years have witnessed significant market disruption fueled by trade tensions, economic policy uncertainty, and global health crises, underscoring the need for investment strategies that can withstand significant stress.

Institutional investors face unique challenges within this landscape. Their long-term investment horizons, often perpetual, are coupled with specific liabilities, such as pension payments, or spending requirements necessary to fulfil an endowment’s or foundation’s mission. Compounding these challenges are stringent fiduciary duties and often complex governance structures involving boards, investment committees, and staff. 

Traditional diversification, while a cornerstone of portfolio construction, has shown limitations during severe market stress, where correlations across asset classes can unexpectedly converge, diminishing diversification benefits when they are most needed. This reality necessitates a more robust and resilient policy framework that goes beyond standard diversification practices.

 

Beyond Compliance: The IPS as a Strategic Resilience Tool

The Investment Policy Statement (IPS) serves as the foundational governance document for any institutional investment programme. It is a written document, typically drafted between the asset owner (e.g., board, committee) and the investment manager or consultant, outlining the investment goals, risk tolerance, time horizon, and constraints governing the portfolio.

However, a truly resilient IPS transcends mere compliance or rule-setting. A well-designed IPS functions as a strategic guide and a roadmap, providing clarity and direction, particularly during periods of market turbulence and uncertainty. It anticipates potential governance issues, guides asset allocation planning, informs implementation, establishes monitoring protocols, defines risk management procedures, and clarifies reporting requirements. This contrasts sharply with generic, template-based IPS documents, which often fail to capture the unique circumstances and nuances critical to an institution’s specific situation. Developing a genuinely useful policy guide requires a deep and thorough understanding of the investor’s specific objectives, constraints, risk tolerances, and preferences.

 

Anchoring Decisions in Chaos: Preventing Value-Destructive Reactions

Perhaps the most critical function of a resilient IPS manifests during market crises. Its primary role in such times is to serve as an objective course of action, preventing emotional, knee-jerk reactions, such as panic selling during downturns or chasing unsustainable rallies—that can significantly damage long-term performance. The IPS provides the necessary discipline to adhere to the long-term strategy even when short-term market movements are extreme and unsettling.

Historical market events offer stark reminders of the consequences of lacking policy discipline. The Global Financial Crisis (GFC) of 2008-2009 saw many investors crystallise losses by selling assets at depressed prices, only to miss subsequent recoveries. In contrast, during the initial phases of the COVID-19 pandemic, institutions with well-defined plans and established trust in their processes reported less panic and greater adherence to their long-term strategies. 

The true value of the IPS is often most apparent precisely when it is most needed – during periods of chaos. It functions as a vital pre-commitment device, safeguarding the investment programme against the behavioural biases, such as loss aversion and herding, that are inevitably amplified under stress. By establishing an objective, pre-agreed course of action, the IPS provides a rational anchor in the storm, enabling fiduciaries to navigate turbulence with greater clarity and purpose.

Building a Resilient Investment Policy in Uncertain Markets Acclimetry

Foundational Pillars of a Resilient Investment Policy Statement

A resilient IPS is built upon several foundational pillars, each requiring careful consideration and explicit definition to ensure the framework can withstand market pressures and guide decision-making effectively over the long term.

 

Defining Purpose, Objectives, and Constraints with Foresight

The starting point for any robust IPS is a clear articulation of the investment pool’s fundamental purpose and its connection to the overarching mission of the institution. For a pension fund, the purpose is primarily to meet benefit obligations to participants and beneficiaries. 

For an endowment or foundation, it is typically to provide a stable and growing stream of income to support operational needs or specific programmes, often while preserving the purchasing power of the principal in perpetuity. Explicitly linking the investment programme to the institutional mission provides essential context for all subsequent policy decisions.

Following the statement of purpose, the IPS must define specific, measurable, achievable, relevant, and time-bound (SMART) investment objectives. These often take the form of target rates of return, such as exceeding the Consumer Price Index (CPI) by a certain percentage (e.g., CPI + 5%) to maintain purchasing power, meeting or exceeding the actuarially assumed rate of return for a pension plan, or achieving a specific real return target. 

The process for setting these objectives should be grounded in realistic capital market assumptions (CMAs) and consider the institution’s spending policy or liability profile. Incorporating uncertainty around return estimates, rather than relying solely on point forecasts, is crucial for building resilience.

Equally important is the comprehensive identification and documentation of all relevant constraints. These typically include:

  • Time Horizon: Often perpetual for endowments and foundations, but may be finite for specific funds.
  • Liquidity Requirements: Ongoing needs for cash to meet operating expenses, grant payments, benefit distributions, capital calls, or other obligations.
  • Legal and Regulatory Framework: Compliance with relevant laws and regulations such as ERISA, UPMIFA, state statutes, or specific tax considerations.
  • Unique Circumstances: Any specific institutional policies, such as socially responsible investing (SRI) or environmental, social, and governance (ESG) mandates, prohibitions on certain asset classes (e.g., tobacco, certain weapons manufacturers), restrictions on leverage, or limitations on foreign securities.

 

Constraints should not be viewed merely as limitations but as essential inputs that define the feasible operating space for the investment strategy. Explicitly addressing these factors upfront ensures that the chosen strategy is not only aligned with the institution’s mission and objectives but also practical and sustainable within its specific operational, legal, and ethical context. Ignoring constraints, particularly around liquidity or regulatory requirements, can lead to severe operational failures or compliance breaches, especially during periods of market stress.

 

Quantifying Risk Tolerance: Establishing Clear Bands for Volatile Times

A cornerstone of a resilient IPS is a clear and, where possible, quantitative definition of risk tolerance. Vague statements like “moderate risk tolerance” are insufficient guides during market turmoil. Instead, the IPS should strive to define risk tolerance using measurable parameters relevant to the institution’s specific context.

It is crucial to distinguish between risk appetite (the willingness to take risk), risk tolerance (the acceptable boundaries or level of risk), and risk capacity (the financial ability to withstand losses). The IPS must reflect a realistic assessment of all three, ensuring that the willingness to take risks does not exceed the capacity to absorb potential negative outcomes. Factors influencing these elements include the investment time horizon, the institution’s financial stability and reliance on investment returns, stakeholder objectives, past experiences with volatility, and the regulatory environment.

Quantification can take various forms:

  • For Defined Benefit Pension Plans: Surplus volatility (standard deviation of asset returns relative to liability returns) is a common metric.
  • For Endowments/Foundations: Metrics might include the probability of loss over a defined period (e.g., less than X% chance of negative return over 3-5 years), maximum acceptable drawdown limits, or constraints on spending volatility.
  • General Measures: Value-at-Risk (VaR) or Expected Shortfall (ES) can quantify potential downside risk under specific confidence levels. Overall portfolio volatility targets, perhaps relative to peers or expressed as an absolute cap, can also be used.

 

Establishing explicit risk bands or ranges around these target metrics is a key operational step. These bands acknowledge that some fluctuation is normal but define the thresholds beyond which risk is considered excessive, triggering predefined actions like portfolio rebalancing or risk reduction measures. This applies not only to overall portfolio risk but also to the drift of asset class weights relative to their strategic targets. 

Furthermore, the IPS should explicitly state the institution’s tolerance for loss or negative events that can be reasonably quantified, forcing a pragmatic discussion about downside protection needs. Quantifying risk tolerance transforms it from a subjective preference into an operational parameter embedded within the investment process. By defining explicit bands and triggers, the IPS removes ambiguity and reduces the potential for emotionally driven decisions when markets become volatile. This linkage between risk tolerance, institutional objectives (like funding status or spending stability), and operational triggers (like rebalancing bands) is fundamental to building a policy that provides genuine guidance during periods of stress.

 

Strategic Asset Allocation (SAA): The Long-Term Anchor in Turbulent Seas

The Strategic Asset Allocation (SAA) is widely recognised as the most significant determinant of long-term portfolio risk and return characteristics. It represents the long-term, baseline mix of asset classes designed to achieve the institution’s objectives within its defined risk tolerance and constraints.

The IPS must clearly articulate the SAA framework, specifying target weights for each approved asset class (e.g., public equity, fixed income, real assets, private equity, absolute return) and, critically, defining permissible ranges or tolerance bands around these targets. These ranges serve multiple purposes: they accommodate natural market drift, provide scope for disciplined tactical adjustments, and define the thresholds for portfolio rebalancing. The IPS may specify these ranges within the main body or, for easier updating, in an appendix.

The development of the SAA itself involves combining the objectives and constraints outlined in the IPS with forward-looking capital market expectations (CMEs) regarding the risk, return, and correlation characteristics of various asset classes. The IPS should ideally address the key assumptions underlying the CME development process. Modern approaches to SAA increasingly incorporate uncertainty and scenario analysis rather than relying solely on point estimates for CMEs.

Finally, the IPS should define a clear policy benchmark that accurately reflects the SAA. This benchmark serves as the primary reference point for evaluating the performance of the total fund relative to its strategic intent and is crucial for communication and accountability.

The SAA, therefore, acts as the strategic anchor for the entire investment programme, translating the institution’s long-term risk tolerance and return objectives into a concrete portfolio structure. 

The explicitly defined ranges around the SAA targets are fundamental to resilience; they establish the pre-approved boundaries within which the portfolio can fluctuate due to market movements and within which deliberate, short-term tactical adjustments or dynamic risk budgeting decisions can be made. This ensures that any flexibility exercised remains firmly tethered to the long-term strategic framework, preventing tactical deviations from becoming unmanaged strategic drift.

 

Table 1: Core Components of a Resilient IPS Framework

IPS Component

Standard Element

Resilience Enhancement Focus

Purpose & Objectives

Statement of mission, return goals, and time horizon

Explicit link to mission, quantifiable & realistic return objectives (considering uncertainty), alignment with liabilities/spending needs 

Constraints

Liquidity needs, legal/regulatory, tax status, unique circumstances (ESG/SRI)

Comprehensive identification, stress-testing liquidity needs, clear definition of regulatory impact (e.g., ERISA), specific ESG integration mandate if applicable 

Risk Tolerance

General statement on risk appetite

Quantification: Define tolerance using metrics (surplus volatility, drawdown limit, VaR/ES, spending volatility) & establish explicit risk bands/ranges 

Strategic Asset Allocation

Target asset class weights

Define clear target weights and permissible ranges (tolerance bands); specify policy benchmark linked to SAA; address CME assumptions 

Liquidity Management

General statement on maintaining liquidity

Formal Contingency Funding Plan (CFP): Identify stressed outflows, pre-arranged/tested funding sources (credit lines, etc.), liquidity tiers/buckets 

Tactical Adjustments

May allow for tactical shifts

Defined Ranges & Governance: Explicit TAA ranges within SAA bands; clear triggers, decision authority, approval process, monitoring, and exit criteria 

Dynamic Risk Budgeting

(Often not explicitly addressed)

Define risk budget (absolute or active); establish framework for dynamic adjustment based on market conditions; specify metrics, authority, process 

Governance & Monitoring

Defines roles, responsibilities, and reporting

Clear IC Charter, bias mitigation techniques, defined crisis decision protocols, integration with monitoring technology (compliance/drift alerts) 

Review Process

Periodic review schedule

Formal annual review minimum; triggers based on material changes (internal/external); version control for institutional memory 

Building Shock Absorbers: Key Resilience Mechanisms within the IPS

Beyond the foundational pillars, a truly resilient IPS incorporates specific mechanisms designed to absorb market shocks and manage deviations from the long-term plan in a disciplined manner. These include robust liquidity contingency planning, clearly defined boundaries for tactical flexibility, and potentially more sophisticated dynamic risk budgeting frameworks.

 

Liquidity Contingency Planning: Preparing for the Unexpected Drawdown

Adequate liquidity is essential for institutional investors to meet their obligations, whether predictable (like benefit payments or grant distributions) or unpredictable (like capital calls or margin calls during market stress). Market crises, such as the GFC and the early stages of the COVID-19 pandemic, starkly demonstrated that liquidity can evaporate quickly and unexpectedly, even in markets traditionally considered liquid. Consequently, relying solely on the assumed liquidity of portfolio assets is insufficient.

A resilient IPS must therefore incorporate a formal, written Contingency Funding Plan (CFP). This plan moves beyond simply acknowledging liquidity needs to proactively outlining specific strategies and procedures for addressing potential liquidity shortfalls under various plausible stress scenarios. Regulatory bodies and industry best practices increasingly emphasise the critical importance of CFPs.

Key elements of a robust CFP framework within or alongside the IPS include:

  • Identifying Potential Stress Events: Defining plausible scenarios (market-wide, institution-specific, combined) that could trigger liquidity needs.
  • Quantifying Potential Needs: Estimating the magnitude and duration of potential liquidity shortfalls under these stress scenarios, often through cash flow projections and stress testing.
  • Identifying and Assessing Contingent Funding Sources: Listing specific backup liquidity sources, such as committed lines of credit from banks, access to central bank facilities (e.g., Federal Reserve Discount Window), repurchase agreements, potential asset sales (considering haircuts and timeframes under stress), or inter-affiliate funding arrangements. The reliability and operational readiness of these sources under stress must be assessed.
  • Operational Readiness and Testing: Establishing clear procedures, lines of authority, and triggers for activating the CFP. Crucially, the operational readiness to access contingent funding sources (e.g., collateral pledging processes, documentation) should be periodically tested to ensure they are truly available when needed.
  • Liquidity Buffers: Determining the appropriate size and composition of a dedicated liquidity buffer, typically consisting of unencumbered, high-quality liquid assets (HQLA) like cash, government securities, or other readily marketable instruments, sufficient to meet stressed outflows over a defined period (e.g., 30 days).

 

A practical way to structure liquidity management is through a tiered or bucketed approach. This involves segmenting assets based on their expected liquidation horizon and purpose:

  • Tier 1 (Operating Liquidity): Cash and highly liquid money market instruments to meet immediate, day-to-day operational needs and benefit payments.
  • Tier 2 (Contingency Reserve): Highly liquid, high-quality securities (e.g., short-term government or high-grade corporate bonds) readily available to meet unexpected shortfalls or margin calls without significant price impact.
  • Tier 3+ (Strategic/Return-Seeking Assets): Less liquid assets (public equities, private markets, real assets) managed for long-term growth, with the understanding that liquidation during stress may be costly or impractical.

 

Liquidity stress testing is integral to validating the CFP and determining the adequacy of liquidity buffers. Methodologies involve projecting cash flows under various adverse scenarios (e.g., significant redemption shocks, asset fire sales, collateral calls, loss of funding access) over different time horizons (e.g., daily for immediate needs, 30 days, 90 days, longer-term). Reverse stress testing, which identifies the severity of shock required to exhaust liquidity resources, can also provide valuable insights.

The increasing focus on formal CFPs and rigorous stress testing reflects a fundamental shift in liquidity management. It moves from a passive assessment of existing assets towards a dynamic, forward-looking process centred on operational readiness and securing reliable funding sources before a crisis hits. This “prepare for the worst” approach is a critical component of building genuine portfolio resilience.

 

Table 2: Liquidity Stress Testing Considerations

Consideration

Description

Relevance for Resilience

Scenario Types

Market-wide (e.g., sharp interest rate rise, equity crash, credit freeze), Idiosyncratic (e.g., large redemption, rating downgrade, reputational damage), Combined 

Assesses vulnerability to different types of shocks, ensuring preparedness beyond just general market downturns. Combined scenarios test resilience under severe, multi-faceted stress.

Time Horizons

Intraday, 5-day, 30-day, 90-day, 1-year+ 

Matches testing to different types of liquidity needs (e.g., immediate margin calls vs. sustained benefit payments). Ensures adequacy across short-term crises and prolonged stress periods.

Key Metrics

Projected net cash flows (inflows vs. outflows), Survival horizon, Liquidity buffer adequacy (vs. stressed need), Asset liquidation costs/time, Collateral availability/haircuts 

Quantifies the potential shortfall, the time available before liquidity is exhausted, and the sufficiency of readily available assets. Highlights the cost and feasibility of liquidating assets under pressure.

Data Inputs

Current asset liquidity profile (tiered), Liability/spending outflows, Capital call projections, Derivative margin requirements, Funding source availability/costs, Behavioural assumptions (e.g., deposit run-off rates, credit line drawdowns) 

Ensures the stress test reflects the institution’s specific balance sheet structure, obligations, and potential behavioural responses under stress. Accuracy depends heavily on realistic assumptions.

Contingent Sources

Identification and quantification of backup lines (credit, Fed window, FHLB, repo), Assessment of reliability and operational readiness under stress, Collateral eligibility and pledging process 

Moves beyond theoretical availability to assess the practical likelihood and speed of accessing backup funds during a crisis. Testing operational readiness is crucial.

 

Tactical Asset Allocation (TAA) Ranges: Enabling Disciplined Flexibility

While the SAA provides the long-term anchor, market conditions inevitably present short-term risks and opportunities. Tactical Asset Allocation (TAA) involves making deliberate, temporary deviations from the SAA targets to capitalise on perceived market mispricings or to defensively adjust exposures based on near-term forecasts. TAA differs fundamentally from portfolio rebalancing, which aims simply to bring drifted allocations back to their SAA targets. TAA is an active management strategy intended to add incremental value or manage risk over shorter horizons, typically with the expectation of returning to the SAA baseline once the tactical opportunity or threat has passed.

For TAA to be a source of resilience rather than a source of unmanaged risk, it must operate within a clearly defined and rigorously governed framework established within the IPS. Key components include:

  • Permissible Ranges: The IPS must explicitly define the allowable ranges (or tolerance bands) around the SAA target weights for each asset class. These ranges set the maximum permissible deviation for tactical bets. Tactical shifts are typically modest, often within 5% to 10% of the SAA target, as larger shifts might indicate a need to revisit the SAA itself. These ranges can be expressed in absolute terms (e.g., +/- 5% from target) or relative terms (e.g., +/- 10% of the target weight), with relative bands often being more practical for smaller allocations.
  • Governance Framework: A critical element often overlooked is the governance process surrounding TAA decisions. The IPS or associated committee charters must specify:
    • Decision Authority: Who is authorised to make TAA decisions? The CIO? The Investment Committee? A dedicated TAA subcommittee?.
    • Activation Triggers/Rationale: What conditions or analyses trigger consideration of a tactical shift? Is it based on quantitative models, qualitative macroeconomic assessments, specific market signals, valuation metrics, or a combination?. The rationale for any tactical decision should be documented.
    • Approval Process: What is the process for approving a tactical shift? Does it require a formal committee vote, or is it delegated within certain parameters?.
    • Monitoring and Evaluation: How are TAA decisions monitored for effectiveness and adherence to ranges? What metrics are used to evaluate the value added (or subtracted) by TAA?.
    • Exit Strategy/Review: How and when are tactical positions reviewed and unwound? Is there a time limit or a specific target outcome that triggers a return to the SAA baseline?.
  • Implementation: While the IPS focuses on policy, a brief acknowledgement of implementation methods (e.g., using physical assets, ETFs, or derivatives like futures and swaps for capital efficiency) and associated considerations (transaction costs, tracking error, liquidity) can be relevant.

 

Without a strong governance framework embedded in the IPS, TAA risks devolving into undisciplined market timing, an activity that research suggests often detracts from long-term returns. Defining clear ranges, triggers, decision authority, documentation requirements, and review processes transforms potential ad-hoc bets into a structured, albeit active, component of the overall investment strategy, ensuring flexibility remains anchored and accountable.

 

Table 3: TAA Activation Governance Checklist

Governance Question

Considerations & Examples

Rationale for Resilience

1. What triggers a TAA decision?

Quantitative signals (e.g., valuation models, momentum indicators, risk regime shifts)? Qualitative assessment (e.g., macroeconomic forecasts, geopolitical events)? Combination? Defined thresholds? 

Ensures TAA is based on predefined criteria, not reactive impulses. Reduces the likelihood of chasing noise or succumbing to market sentiment.

2. Who has decision authority?

CIO? Investment Committee? Dedicated TAA subcommittee? Delegated to an external manager within specific guidelines? 

Clarifies accountability. Ensures decisions are made by individuals/groups with appropriate expertise and mandate. Prevents unauthorised or ad-hoc bets.

3. What analysis/rationale is required?

Documented investment thesis? Expected risk/return impact analysis? Scenario analysis? Alignment with overall IPS objectives? 

Promotes disciplined, evidence-based decision-making. Allows for post-hoc evaluation of the decision process, not just the outcome.

4. What is the approval process?

CIO discretion within pre-approved bands? Committee discussion/vote required? Notification process? 

Balances need for timely action with appropriate oversight. Ensures key stakeholders are informed and/or approve significant deviations.

5. How are TAA decisions documented?

Formal investment memo? Committee minutes? Trade logs? 

Creates an audit trail for compliance and governance. Facilitates review and learning from past decisions. Supports institutional memory.

6. How is TAA performance monitored/evaluated?

Attribution analysis (vs. SAA benchmark)? Information ratio? Impact on total portfolio risk/return? Frequency of review? 

Assess the effectiveness of the TAA strategy. Identifies whether TAA is adding value relative to the risks taken. Informs future TAA decisions and process improvements.

7. What are the exit criteria/review triggers?

Predefined time horizon? Target price/valuation reached? Change in triggering conditions? Stop-loss levels? Regular review schedule? 

Ensures tactical positions are temporary and don’t become unintended long-term strategic shifts. Provides discipline for cutting losses or taking profits.

 

Dynamic Risk Budgeting: Adapting Risk Exposure to Market Conditions

An evolution of, or complement to, traditional TAA is dynamic risk budgeting. Instead of primarily focusing on shifting capital allocations, risk budgeting allocates and manages the portfolio based on the contribution of different assets or factors to the overall portfolio risk. It forces an explicit consideration of where risk originates and the expected compensation for bearing that risk.

Key aspects of risk budgeting relevant for a resilient IPS include:

  • Focus on Risk Allocation: The core idea is to allocate a “budget” of risk (e.g., measured by volatility, tracking error, VaR, or Expected Shortfall) across different portfolio components.
  • Active vs. Absolute: Risk budgeting can target the absolute risk of the total portfolio or, more commonly for institutional investors managing against an SAA, the active risk (tracking error) relative to the policy benchmark. Active risk budgeting focuses on managing the risk introduced by deviations from the SAA, whether through asset allocation tilts or manager selection.
  • Dynamic Adjustment: The power of risk budgeting for resilience lies in its potential for dynamic adjustment. The overall risk budget, or the allocation of risk within the budget, can be systematically increased or decreased based on assessments of the market environment, economic outlook, and asset valuations. For instance, the risk budget might be increased (allowing for greater deviation from the benchmark or higher overall volatility) when conditions are deemed favourable and reduced during periods of heightened uncertainty or expensive valuations.
  • Implementation Tools: Implementation relies on robust risk modelling capabilities to measure risk contributions accurately. Common metrics include standard deviation, VaR, ES, and component risk contributions. Some managers use proprietary metrics like Fort Washington’s Index-Equivalent Spread Duration (IESD) for fixed income. Factor-based risk budgeting, allocating risk across underlying factors (e.g., value, momentum, credit) rather than just asset classes, is also gaining traction. Implementation can be challenging, particularly for illiquid private market assets where risk measurement is less straightforward.
  • Governance: As with TAA, implementing a dynamic risk budgeting framework requires clear governance defined within the IPS. This includes defining the overall risk budget (e.g., maximum tracking error), the methodology and metrics used, the process and authority for adjusting the budget or its allocation, and ongoing monitoring and reporting procedures.

 

Dynamic risk budgeting provides a more sophisticated lens for implementing tactical views. By focusing explicitly on the allocation and adjustment of risk, rather than just capital, it allows for a more nuanced and potentially more robust way to navigate changing market conditions and systematically adapt the portfolio’s risk posture within the boundaries set by the IPS. It encourages a disciplined consideration of the risk-reward trade-off inherent in any deviation from the long-term strategic allocation.

Learning from History: Lessons from Market Crises (e.g., 2008 GFC, COVID-19 Pandemic)

Market crises serve as real-world stress tests, revealing weaknesses in investment policies, governance structures, and operational capabilities. The Global Financial Crisis (GFC) of 2008-2009 and the COVID-19 pandemic onset in 2020, while different in origin—one rooted in the financial system (credit crisis), the other in a global health emergency triggering a liquidity crisis—offer valuable lessons for building more resilient institutional investment frameworks. Examining institutional responses and outcomes during these periods highlights critical elements for effective policy design.

 

Lesson 1: The Value of Investment Discipline & Pre-Commitment

A stark contrast emerged between institutional responses in 2008 and 2020 regarding investment discipline. The GFC saw widespread instances of institutions deviating from long-term strategies, often selling assets at deeply depressed prices due to panic or forced liquidation, thereby locking in losses and missing subsequent market recoveries. By 2020, however, many institutional investors demonstrated greater discipline. 

Having experienced the pain of “de-risking at the bottom” in 2008, many boards and investment committees showed a stronger resolve to adhere to their pre-agreed investment policies. Anecdotal evidence suggests that boards, having previously discussed crisis response plans embedded in their IPS, trusted their investment teams to execute the strategy rather than demanding reactive changes. 

This underscores the power of a well-communicated and trusted IPS as a pre-commitment device, providing the necessary anchor and guidance to resist emotional decision-making during periods of extreme stress.

 

Lesson 2: Liquidity Management is Paramount

Both crises underscored the critical importance of robust liquidity management, but the nature of the challenge differed. While the GFC involved a credit freeze, the March 2020 turmoil was characterised as a “dash for cash,” exposing vulnerabilities across various market segments, including traditionally liquid ones like government bonds. Weaknesses in liquidity planning and preparedness were identified as key issues. 

The UK’s LDI (Liability-Driven Investment) crisis in 2022 further highlighted the liquidity risks associated with leveraged derivative positions when collateral calls surge unexpectedly. While post-GFC reforms, including enhanced liquidity risk management rules for some entities, likely contributed to a more resilient system overall, the 2020 events demonstrated that significant vulnerabilities persist, particularly within the non-bank financial intermediation (NBFI) sector. The key takeaway is the reinforced need for proactive liquidity contingency planning, including formal CFPs, rigorous stress testing across plausible scenarios, and ensuring the operational readiness of backup funding lines.

 

Lesson 3: Diversification & Risk Factors

Crises often challenge traditional diversification assumptions as correlations spike. The 2020 turmoil highlighted the importance of managing portfolio exposures through a factor lens, as common factor movements drove a significant portion of volatility, making factor management potentially more critical than individual security selection during the peak stress period. Strategies explicitly designed for risk mitigation, such as CalSTRS’ Risk Mitigating Strategies (RMS) portfolio, demonstrated their value by providing positive returns during equity market drawdowns, offering a source of liquidity and capital for rebalancing. 

There is also evidence suggesting that companies with strong Environmental, Social, and Governance (ESG) characteristics exhibited greater resilience and smaller drawdowns during the COVID-19 crisis, potentially due to better risk management or investor preference for perceived “safer” assets during turmoil. However, the long-term performance benefits of ESG remain a subject of ongoing research and debate. Global diversification also proved beneficial, as the crisis impacted regions and sectors unevenly.

 

Lesson 4: Governance and Operational Effectiveness

Market crises act as a powerful litmus test for the effectiveness of an institution’s governance framework and operational capabilities. Weaknesses in risk management processes, unclear roles and responsibilities, slow decision-making structures, and inadequate oversight were identified as contributing factors in exacerbating problems during recent stress events. 

The ability to maintain stakeholder trust, ensure business continuity (e.g., remote work capabilities), and effectively monitor rapidly changing portfolio risks proved crucial. Institutions with clear lines of authority, well-understood processes (like rebalancing thresholds), and strong communication between investment staff, committees, and boards navigated the challenges more effectively.

 

Case Study Insights (e.g., CalPERS/CalSTRS/Yale)

The experiences of large, sophisticated institutional investors provide practical context. For example, CalSTRS’ deliberate implementation of its RMS portfolio, designed specifically to mitigate equity drawdowns, proved valuable during the 2020 and 2022 downturns, providing liquidity and cushioning overall fund performance. 

CalPERS’ ongoing debates regarding divestment decisions (e.g., tobacco, fossil fuels) highlight the tension between financial performance, fiduciary duty, and stakeholder values, emphasising the importance of a clear process and rationale for such policy decisions, rather than relying solely on hindsight performance analysis. Yale’s long-term success, often attributed to its pioneering adoption of the “Endowment Model” with significant allocations to alternatives, also faced challenges during the GFC, leading many institutions, including Yale itself, to refine risk management practices and liquidity considerations.

Ultimately, the lessons from historical crises converge on a central theme: resilience is built through proactive planning, disciplined execution anchored in a robust policy, and effective governance capable of navigating complexity and mitigating behavioural biases. Reactive adjustments during turmoil are often suboptimal; the foundation for weathering the next storm must be laid during periods of relative calm.

Governance and Monitoring: Ensuring Policy Adherence and Effectiveness

A well-drafted IPS is necessary but not sufficient for resilience. Its effectiveness hinges on robust governance structures and diligent monitoring processes that ensure the policy is consistently adhered to, remains relevant, and guides decision-making in practice, especially under pressure.

 

The Investment Committee’s Role: Best Practices in Oversight and Crisis Decision-Making

The investment committee (IC) plays a pivotal role in the governance framework. Best practices emphasise that the IC’s primary function is oversight and policy-setting, ensuring that the investment programme operates in compliance with the IPS and achieves its objectives, rather than engaging in day-to-day investment management or security selection, unless this is explicitly part of a defined, resource-appropriate model. A clear definition of the IC’s roles, responsibilities, authority, and limitations within an Investment Committee Charter and the IPS itself is paramount.

Effective ICs establish and adhere to disciplined decision-making processes for key strategic issues like SAA reviews, manager selection and termination, TAA activation, risk budget adjustments, and IPS updates. Utilising structured meeting agendas, ensuring adequate preparation, and fostering open, constructive debate are hallmarks of effective committee operations.

A critical aspect of IC governance is recognising and actively mitigating the influence of behavioural biases. Committees, like individuals, are susceptible to cognitive errors (e.g., anchoring, confirmation bias, overconfidence) and emotional biases (e.g., loss aversion, regret aversion, herding/groupthink) that can lead to suboptimal decisions, particularly under stress. Practical mitigation techniques should be embedded in the committee’s culture and processes.

 

Table 4: Investment Committee Behavioural Bias Mitigation Techniques

Behavioural Bias

Description

Practical Mitigation Techniques

Overconfidence Bias

Overestimating own abilities, knowledge accuracy, or control over outcomes 

Cultivate humility; rigorous, data-driven analysis; “premortem” analysis (imagining failure scenarios); seek diverse/external perspectives; focus on process quality, not just past success 

Loss Aversion

Feeling the pain of losses more acutely than the pleasure of equivalent gains, leading to holding losers too long 

Predetermined exit strategies/criteria in IPS; objective evaluation based on current fundamentals, not purchase price; focus on overall portfolio goals, not individual holdings; systematic review process 

Herding / Groupthink

Following group behaviour or conforming to avoid conflict, suppressing dissenting views.

Encourage diversity (cognitive, experiential); strong chair actively solicits all views; assign a “devil’s advocate” role; foster a culture of constructive challenge; anonymous feedback mechanisms 

Anchoring Bias

Relying too heavily on the first piece of information received (e.g., initial price, past trend) 

Actively seek out new information and perspectives; challenge initial assumptions; focus analysis on current data and forward-looking expectations; use multiple valuation methods/benchmarks 

Confirmation Bias

Seeking out or overweighing information that confirms pre-existing beliefs, ignoring contradictory evidence 

Actively seek opposing viewpoints/contrary evidence; challenge assumptions; use objective benchmarks; structured debate formats; focus on disconfirming evidence 

Regret Aversion

Avoiding decisions that might lead to future regret, potentially causing inaction or slow execution 

Focus on the decision-making process, not just the outcome; frame decisions within the long-term strategy; acknowledge that uncertainty is inherent; establish clear action thresholds 

 

During crises, the IC’s adherence to the established IPS framework is paramount. Pre-defined contingency plans, TAA triggers, risk protocols, and rebalancing rules provide the necessary structure to guide actions rationally. The focus should remain on long-term objectives, resisting the urge to make ad-hoc strategic changes based on short-term fear or market noise. 

Effective committee governance, therefore, is not merely about expertise; it is about designing and adhering to processes that manage complexity and counteract predictable human errors, particularly when stakes are high.

 

The IPS Review Cycle: Keeping the Policy a Living Document

To maintain its relevance and effectiveness, the IPS cannot be a static document “set and forgotten” on a shelf. A resilient investment programme requires a defined process for periodically reviewing and, when necessary, updating the IPS.

 

Best practices dictate regular reviews, typically conducted at least annually, with some recommending inclusion in quarterly committee agendas. More comprehensive reviews might occur every 3-5 years, coinciding with market cycles or strategic planning horizons. Beyond scheduled reviews, updates should be triggered by material changes in the institution’s circumstances, such as shifts in objectives, liabilities, spending needs, risk tolerance, or organisational structure, or by significant, potentially structural changes in capital market assumptions or the regulatory landscape.

The purpose of these reviews is not to encourage frequent, reactive changes to the core strategy, which can be detrimental. Rather, it is to reaffirm the alignment between the policy, the institution’s current reality, and the long-term objectives, ensuring the IPS remains a relevant and effective guide. It’s an opportunity to confirm that the underlying assumptions still hold and that the documented strategy is still the most appropriate path forward. Ad-hoc revisions outside of this structured process should be strongly discouraged.

Maintaining meticulous records of IPS reviews, amendments, and approvals, including the rationale for changes, is crucial. Implementing version control allows tracking the evolution of the policy over time, providing transparency and valuable context for future committees and stakeholders. The IPS thus serves as a vital repository of organisational memory regarding investment philosophy, risk appetite evolution, and strategic decision-making, ensuring continuity despite inevitable turnover among board members, committee members, or staff. Treating the IPS as a living document, subject to disciplined review and adaptation, ensures it remains a powerful tool for navigating the complexities of institutional investing over the long term.

 

Leveraging Technology: Portfolio Monitoring for Compliance and Drift Management

Ensuring ongoing adherence to the detailed parameters outlined in the IPS—particularly asset allocation ranges, risk limits, and investment restrictions—presents a significant operational challenge for institutional investors. Manually tracking portfolio positions against policy guidelines across potentially numerous managers and complex asset classes is often inefficient, prone to errors, and typically lags real-time market movements, hindering timely intervention when deviations occur.

The emergence of sophisticated portfolio monitoring and management platforms offers a technological solution to bridge this gap between policy and execution. Platforms such as Acclimetry and BlackRock’s Aladdin, among others, are specifically designed to meet the complex needs of institutional investors.

These integrated platforms typically offer functionalities that directly support IPS resilience and governance:

  • Unified Policy and Portfolio Management: They provide a central repository for the IPS document itself, often allowing for template-based creation and digital management of the policy alongside portfolio data.
  • Automated Compliance Monitoring: Rules derived from the IPS (e.g., asset allocation ranges, sector/geographic limits, security restrictions, risk thresholds) can be coded into the system. The platform can then automatically monitor portfolio holdings and transactions (pre- and post-trade) for compliance against these rules.
  • Drift Management and Alerts: These systems continuously track actual portfolio allocations against the SAA and TAA targets defined in the IPS. Visual dashboards and automated alerts notify investment staff or committees when allocations drift outside the permissible tolerance bands specified in the policy, highlighting the need for rebalancing or review.
  • Enhanced Reporting and Audit Trails: Platforms generate comprehensive reports on portfolio status, compliance checks, and performance attribution. They automatically create audit trails, logging policy reviews, approvals, violations, and resolutions, which strengthens governance and aids regulatory compliance.
  • Streamlined Governance Workflows: Digital workflows can automate the process of reviewing, proposing changes to, and approving the IPS, facilitating collaboration among committee members, staff, and advisors.
  • Integration Capabilities: Many platforms integrate with other essential systems, such as Custody, Accounting, CRM, Risk Analytics, and Market Data feeds, creating a more holistic and efficient ecosystem for investment management and oversight.

 

The adoption of such technology fundamentally changes the dynamic of IPS oversight. It transforms the policy from a potentially static reference document into an active, integrated component of the daily investment management workflow. By automating routine monitoring and compliance tasks, these platforms enable timelier detection of deviations and potential risks, facilitate more efficient rebalancing and tactical adjustments, enhance governance oversight, and ultimately free up valuable fiduciary time to focus on higher-level strategic decision-making rather than manual data aggregation and checking. This technological enablement is a key factor in making the principles of a resilient IPS operationally achievable for complex institutional portfolios.

Future-Proofing Your Investment Policy: Emerging Trends and Considerations

Building a resilient IPS is not a one-time task but an ongoing process that requires anticipating and adapting to evolving market dynamics, technological advancements, and shifting stakeholder expectations. Several key trends are shaping the future of investment policy design and governance.

 

Integrating ESG and Climate Risk into the Resilience Framework

Environmental, Social, and Governance (ESG) factors, and particularly the risks associated with climate change, are rapidly moving from the periphery to the core of institutional investment considerations. Driven by increasing evidence of financial materiality, regulatory pressure (such as evolving interpretations of ERISA’s duties of prudence and loyalty ), and demands from beneficiaries and other stakeholders, investors are recognising that these factors can significantly impact long-term portfolio performance and risk.

Integrating these considerations into the IPS framework is becoming a hallmark of forward-looking governance. This involves more than just aspirational statements; it requires embedding ESG and climate considerations into the core elements of the policy:

  • Investment Beliefs/Philosophy: Articulating the institution’s view on the financial relevance of ESG factors and their role in long-term value creation.
  • Objectives and Constraints: Setting specific, measurable ESG or climate-related targets (e.g., portfolio carbon footprint reduction, alignment with net-zero pathways, specific impact goals) or defining ESG-related constraints (e.g., exclusions based on activities or ESG ratings).
  • Asset Allocation: Considering climate risk (both physical and transition risks) in strategic asset allocation modelling and potentially tilting allocations towards climate solutions or lower-carbon strategies.
  • Manager Selection and Monitoring: Incorporating ESG integration capabilities and climate risk management into the due diligence and ongoing monitoring of external managers.
  • Risk Management: Explicitly identifying climate change as a systemic risk and incorporating climate scenario analysis or climate Value-at-Risk (VaR) into the overall risk management framework.
  • Reporting: Committing to transparency through reporting aligned with frameworks like the Task Force on Climate-related Financial Disclosures (TCFD).

 

Framing ESG and climate integration primarily through the lens of long-term risk management and fiduciary duty strengthens the case for its inclusion in a resilience-focused IPS. As climate impacts become more pronounced and the transition to a low-carbon economy accelerates, portfolios unprepared for these shifts face significant long-term risks.

 

The Role of Alternative Data and AI in Enhancing Policy Monitoring and Execution

Technological advancements, particularly in the realms of alternative data and artificial intelligence (AI) / machine learning (ML), are poised to significantly impact investment policy monitoring and execution.

Alternative data sources—ranging from satellite imagery and geolocation data to credit card transactions, app usage statistics, web scraping, and news sentiment analysis—provide insights beyond traditional financial reporting. AI and ML algorithms are increasingly adept at processing these vast, often unstructured datasets to identify patterns, predict market movements or volatility, assess risk, and inform investment decisions.

For IPS governance and resilience, these technologies offer compelling potential:

  • Enhanced Monitoring: AI/ML can analyse portfolio data (including alternative data feeds) in near real-time to monitor compliance with complex IPS constraints, detect anomalies, and flag potential risks or deviations much faster than manual processes.
  • Predictive Compliance: By identifying patterns that often precede policy breaches or heightened risk exposures, AI/ML could potentially move monitoring from reactive detection to proactive prediction.
  • Improved Risk Assessment: AI can incorporate a wider range of data inputs, including non-traditional sources, into risk models and stress tests, potentially providing a more comprehensive view of portfolio vulnerabilities.
  • Automation: Routine monitoring and reporting tasks can be automated, freeing up human resources for more strategic analysis and decision-making.

 

However, adopting these technologies also presents challenges, including ensuring data quality and provenance, managing privacy concerns, mitigating compliance risks (e.g., inadvertent use of material non-public information), addressing model biases, and acquiring the necessary technological infrastructure and data science expertise. Despite these hurdles, the potential for AI, ML, and alternative data to revolutionise IPS monitoring—making it more dynamic, comprehensive, and predictive—suggests this is a critical area for institutional investors to explore for future resilience.

 

Evolving Governance Models and Fiduciary Expectations

Investment governance itself is evolving, driven by increased scrutiny following market crises, heightened regulatory expectations, and a growing body of litigation targeting fiduciary conduct.

A key trend is the formal articulation of Investment Beliefs. These statements, often developed prior to or alongside the IPS, clarify the institution’s fundamental assumptions about how markets work, where value can be added, and the role of risk. Establishing shared beliefs provides a stronger, more coherent foundation for developing the IPS and guiding subsequent decisions.

There is also a growing emphasis on the primacy of process in fulfilling fiduciary duties. Courts and regulators increasingly look not just at investment outcomes, but at the documented processes that fiduciaries follow in making decisions. A well-structured IPS, supported by thorough meeting minutes and documented analysis, serves as crucial evidence of procedural prudence. This underscores the need for rigorous documentation of SAA rationale, manager due diligence, TAA decisions, risk assessments, and IPS reviews.

Finally, the increasing complexity of investment strategies and the rise of outsourcing models (e.g., OCIOs) necessitate clear governance structures for delegation and oversight. While execution can be delegated, fiduciary responsibility cannot. The IPS and related governance documents must clearly define the scope of delegation, the responsibilities of external providers, and the mechanisms through which the investment committee will monitor their performance and compliance.

These trends point towards a future where investment governance is more formalised, transparent, process-driven, and technologically enabled. Incorporating these elements into the IPS framework is essential for meeting evolving fiduciary standards and future-proofing the investment programme.

Conclusion: Building Enduring Value Through a Resilient Investment Policy

In an era defined by heightened uncertainty and rapid market shifts, the Investment Policy Statement transcends its traditional role as a mere compliance document. For pension funds, endowments, and other institutional investors navigating complex liabilities, long time horizons, and stringent fiduciary duties, a thoughtfully constructed and diligently governed IPS emerges as a critical strategic asset, a foundation of resilience.

Building this resilience requires a deliberate and comprehensive approach, moving beyond generic templates to create a policy framework tailored to the institution’s unique circumstances. This involves:

  1. Clarity of Purpose and Quantified Objectives: Anchoring the investment programme in the institution’s mission and defining specific, measurable objectives and constraints, including a quantitatively defined risk tolerance that establishes clear operational boundaries.
  2. Proactive Resilience Mechanisms: Embedding shock absorbers directly into the policy through formal Contingency Funding Plans, rigorous liquidity stress testing, defined liquidity tiers, and disciplined frameworks for tactical asset allocation or dynamic risk budgeting, complete with clear governance structures for activation and oversight.
  3. Learning from Experience: Incorporating lessons from past crises, particularly regarding the imperative of investment discipline, the critical nature of liquidity preparedness, the limitations of traditional diversification, and the impact of governance effectiveness under stress.
  4. Robust Governance and Monitoring: Empowering the investment committee with clear roles, effective decision-making processes designed to mitigate behavioural biases, and a commitment to regular, structured IPS reviews to ensure ongoing relevance.
  5. Leveraging Technology: Utilising modern portfolio monitoring platforms to automate compliance checks, manage allocation drift effectively, streamline governance workflows, and transform the IPS into an active component of the investment process.
  6. Future-Proofing: Proactively integrating emerging considerations like ESG and climate risk into the risk management framework and exploring the potential of AI and alternative data to enhance monitoring and execution, while adapting governance models to meet evolving fiduciary expectations.

 

A resilient IPS is not a guarantee against market downturns or unexpected events, but it provides the essential framework for navigating them effectively. It fosters discipline, prevents value-destructive emotional reactions, ensures alignment among stakeholders, clarifies accountability, and supports the fulfillment of fiduciary duties. By embracing the principles outlined—moving from static rules to dynamic frameworks, from subjective assessments to quantified parameters, and from periodic snapshots to continuous monitoring—CIOs and investment committees can craft investment policies that not only meet compliance requirements but actively contribute to the long-term sustainability and success of their institutions, even in the face of profound uncertainty. The task is not merely to write a policy, but to build and maintain a resilient foundation for enduring value creation.

References

  1. Portfolio Management for Institutional Investors, accessed on May 3, 2025, https://www.cfainstitute.org/insights/professional-learning/refresher-readings/2025/portfolio-management-institutional-investors
  2. Private Wealth Management – CFA Institute, accessed on May 3, 2025, https://www.cfainstitute.org/sites/default/files/-/media/documents/article/refresher-readings-free/rr-2018-l2v6r47.pdf
  3. 2020–21 and 2021–22 Biennial Budget – CalSTRS, accessed on May 3, 2025, https://www.calstrs.com/files/624f589f0/biennialbudget-2020-22.pdf
  4. ELEMENTS OF AN INVESTMENT POLICY STATEMENT FOR INSTITUTIONAL INVESTORS, accessed on May 3, 2025, https://rpc.cfainstitute.org/sites/default/files/-/media/documents/article/position-paper/investment-policy-statement-institutional-investors.pdf
  5. Investment Governance for Fiduciaries: The How and the Why | CFA Institute Enterprising Investor, accessed on May 3, 2025, https://blogs.cfainstitute.org/investor/2019/09/20/investment-governance-for-fiduciaries-the-how-and-the-why/
  6. Risk Control through Dynamic Core-Satellite Portfolios of ETFs: Applications to Absolute Return Funds and Tactical Asset Allocation – CiteSeerX, accessed on May 3, 2025, https://citeseerx.ist.psu.edu/document?repid=rep1&type=pdf&doi=f5c8d5983d187333d5d6612cdda6085e9127ed96
  7. Dynamic Asset Allocation as a Response to the Limitations of Diversification – CAIA, accessed on May 3, 2025, http://www.caia.org/sites/default/files/AIAR_Q3_2016_07_Diversification.pdf
  8. INVESTMENT POLICY STATEMENT – Regents of the University of California, accessed on May 3, 2025, https://regents.universityofcalifornia.edu/regmeet/mar05/fattach.pdf
  9. 1 Investment Policy Statement Example included below (including defined roles and responsibilities, defined percentages, etc.) a – Texas Pension Review Board, accessed on May 3, 2025, https://www.prb.texas.gov/wp-content/uploads/2024/03/Redline-Draft-PRB-IPS-Template-Example.pdf
  10. Crafting a Robust Investment Policy Statement – Acclimetry, accessed on May 3, 2025, https://acclimetry.com/crafting-a-robust-investment-policy-statement/
  11. From Policy to Portfolio: Bridging the Gap Between Investment Policy Statement (IPS) and Investment Execution – Acclimetry, accessed on May 3, 2025, https://acclimetry.com/from-policy-to-portfolio-bridging-the-gap-between-investment-policy-statement-ips-and-investment-execution/
  12. THE RICHLAND COUNTY FOUNDATION OF MANSFIELD, OHIO Investment Policy Statement Approved by the Board of Trustees, accessed on May 3, 2025, https://www.richlandcountyfoundation.org/upload/documents/investment_policy_12-10-18.pdf
  13. investment policy statement – Repositório da Universidade de Lisboa, accessed on May 3, 2025, https://repositorio.ulisboa.pt/bitstream/10400.5/95580/1/DM-CHO-2024.pdf
  14. Liquidity Policy – Commonwealth of Pennsylvania, accessed on May 3, 2025, https://www.pa.gov/content/dam/copapwp-pagov/en/psers/documents/transparency/investment/guide/liquidity%20policy%20adopted%20final.pdf
  15. investment policy statement city of dover employees pension plan, accessed on May 3, 2025, https://www.cityofdover.com/media/Finance/Retirement_Trust_Fund_Reports/General%20Employee%20Pension/08-11-2016-1%20Investment%20Policy%20Statement%20-%20General%20Employee%20Pension%20Plan.pdf
  16. 5 Behavioural Biases That Can Impact Your Investing Decisions, accessed on May 3, 2025, https://online.mason.wm.edu/blog/behavioral-biases-that-can-impact-investing-decisions
  17. Statement of Investment Policy City of El Paso Employees Retirement Trust, accessed on May 3, 2025, https://www.eppension.org/documents/fund-overview/2024-08-21-CEPERT-IPS-Executed.pdf?1743617147
  18. PUBLIC SERVICE PENSION PLAN STATEMENT OF INVESTMENT POLICIES AND PROCEDURES, accessed on May 3, 2025, https://pspp.pensionsbc.ca/documents/824580/824637/%28PDF%29+Statement+of+investment+policies+and+procedures.pdf/c9bfb617-f375-4eb6-a3cd-753ff3638ec3?t=1637257248028
  19. university of california retirement plan – INVESTMENT POLICY STATEMENT, accessed on May 3, 2025, https://www.ucop.edu/investment-office/_files/invpol/UCRP_IPS_05-12-2016.pdf
  20. Policy 7610: Investment Management – UNM Policy – The University of New Mexico, accessed on May 3, 2025, https://policy.unm.edu/university-policies/7000/7610.html
  21. 22 October 2014 Dear IAIS Members: Please find attached the guidance on liquidity management and planning that was drafted by th, accessed on May 3, 2025, https://www.iais.org/uploads/2022/01/Liquidity-guidance-final.pdf
  22. Examination Manual Module – Liquidity – Federal Housing Finance Agency, accessed on May 3, 2025, https://www.fhfa.gov/sites/default/files/2023-03/liquiditymodulefinalversion1_0-508.pdf
  23. Guidance on How to Comply with NCUA Regulation §741.12 Liquidity and Contingency Funding Plans, accessed on May 3, 2025, https://ncua.gov/regulation-supervision/letters-credit-unions-other-guidance/guidance-how-comply-ncua-regulation-ss74112-liquidity-and-contingency-funding-plans
  24. Liquidity Risk Resources | NCUA, accessed on May 3, 2025, https://ncua.gov/regulation-supervision/regulatory-compliance-resources/liquidity-risk-resources
  25. Liquidity booklet, Comptroller’s Handbook, accessed on May 3, 2025, https://www.occ.gov/publications-and-resources/publications/comptrollers-handbook/files/liquidity/pub-ch-liquidity.pdf
  26. INV 092023 Item 05.00 – ExSum – Liquidity Oversight Management – CalSTRS, accessed on May 3, 2025, https://www.calstrs.com/files/b1cfa2342/INV+092023+Item+05.00+-+ExSum+-+Liquidity+Oversight+Management.pdf
  27. Statement of Investment Policies and Objectives For Delaware Public Employees’ Retirement System As amended by the Board of P, accessed on May 3, 2025, https://open.omb.delaware.gov/PDF/InvestmentGuidelines5-30-14.pdf
  28. regents.universityofcalifornia.edu, accessed on May 3, 2025, https://regents.universityofcalifornia.edu/regmeet/july20/i2attach1.pdf
  29. Issue Brief – How Do Public Pensions Invest? A Primer, accessed on May 3, 2025, https://archive.legmt.gov/content/Committees/Interim/2017-2018/State-Administration-and-Veterans-Affairs/Meetings/Jan-2018/how%20public%20pensions%20invest%20final_primer.pdf
  30. Agenda Item 4, accessed on May 3, 2025, https://www.treasurer.ca.gov/able/meeting/2025/0318/4.pdf
  31. INV 012024 Item 05.00 – ExSum – Investment Policy Statement Revision Leverage & Asset Allocation Bands – CalSTRS, accessed on May 3, 2025, https://www.calstrs.com/files/ac2e180d3/INV+012024+Item+05.00+-+ExSum+-+Investment+Policy+Statement+Revision+Leverage+%26+Asset+Allocation+Bands+%E2%80%93+First+Reading.pdf
  32. ICANN Investment Policy | Adopted November 2007 | Updated July 2009, accessed on May 3, 2025, https://www.icann.org/resources/pages/investment-policy-2021-07-27-en
  33. Transformative Lessons from the 2025 Investment Portfolio Case Competition, accessed on May 3, 2025, https://business.cornell.edu/article/2025/02/lessons-from-the-investment-portfolio-case-competition/
  34. INVESTMENT POLICY STATEMENT – Ball State University, accessed on May 3, 2025, https://www.bsu.edu/-/media/www/departmentalcontent/controller/pdf/cash-investment/ball-state-university—ips—2021.pdf?sc_lang=en&hash=3FFC8A1044BCE6F2E395054DE0E9C8DD185A3822
  35. Consultation on supervising the liquidity risk management of IORPs – EIOPA, accessed on May 3, 2025, https://www.eiopa.europa.eu/consultations/consultation-supervising-liquidity-risk-management-iorps_en
  36. EIOPA seeks feedback on measures aimed at strengthening the supervision of occupational pension funds’ liquidity management, accessed on May 3, 2025, https://www.eiopa.europa.eu/eiopa-seeks-feedback-measures-aimed-strengthening-supervision-occupational-pension-funds-liquidity-2024-09-26_en