Policy clause
"Managers confirm compliance with the guidelines each quarter": how to write it, test it and evidence it
A compliance certificate makes each manager state, every quarter, that the portfolio met its guidelines. Acclimetry holds it as a quarterly manual obligation whose attestation captures the answer, any exceptions and the signed certificate. The certificate complements monitoring: measurable guidelines are tested as rules, and a no answer opens a case.
Each investment manager will confirm in writing, within 15 days of each quarter-end, that the portfolio complied with these guidelines throughout the quarter.
manual_obligationQuestions to settle before it can be tested
- Throughout or at quarter-end: a certificate as at one date says nothing about the weeks between.
- At purchase or continuously: some guidelines apply only when a security is bought, and the certificate should say which.
- Exceptions: a certificate listing reported exceptions is not a failure; the fields should capture each one.
- Reliance: a certificate does not replace monitoring of the measurable guidelines.
As a testable rule
Manual obligation, frequency quarterly, due 15 days after each quarter-end, asking for a yes-or-no answer, any exceptions and the signed certificate. A no answer is configured as a failure. A manual-obligation rule follows the obligation with a 7-day warning window.
A testable wording
Within 15 days of each quarter-end, each manager will certify that the portfolio complied with these guidelines on every business day of the quarter. The certificate lists any exception and when it was reported.
See attestations and the attestation record template.
Worked example
The third-quarter certificate is due on 15 October and not yet submitted: on 12 October, three days out, the rule reads a warning.
Rule template:manual_obligation obligationId: 6aaf00000000000000000039warnWithinDays: 7
| Obligation | Frequency | Latest task | Next due |
|---|---|---|---|
| Quarterly guideline compliance certificate | quarterly | pending, due 15 October 2026 | 15 October 2026 |
| Group | Status | Value | Bounds | Headroom to the hard bound | Code |
|---|---|---|---|---|---|
| Quarterly guideline compliance certificate | Warning | 0 | – | – | OBLIGATION_DUE_SOON |
OBLIGATION_DUE_SOON: The obligation falls due within the rule's warning window and is not yet complete.
Computed at build time by the Acclimetry rule engine (backend commit 8197063); the same code runs in the product.
What each monitoring run records
Each certificate is stored with the manager's answers, the attachment, the reviewer's approval and timestamps. A failed answer, a rejected certificate or a missed due date opens a case. The certificates sit beside the rule results for the same quarter in the evidence record.