Post Summary
That advanced data analysis can detect complex operational risk patterns in alternative asset managers that are otherwise invisible, similar to how Google's AlphaGo program detected patterns in the game Go that were invisible to its human opponent.
8% of alternative asset advisers incurred a regulatory violation over a recent 36-month period, and 80% of those violators had a medium or high complexity profile prior to their regulatory issues surfacing.
That complex systems can add risk, and unnecessarily complex systems can add unnecessary risk, meaning investors and allocators should want to know that a manager's systems are commensurate with the fund's inherent operational risk.
As much as a terabyte a day, drawn from a publicly accessible digital footprint that includes ADV filings, vendor relationships, and RFPs.
More than 17,000 registered investment advisers, 58,000 alternative funds, an expected $20 trillion in assets by year-end 2020, and 40,000 ADVs filed by alternative asset managers in 2016, of which 40% were filed more than once.
This post, written by Convergence's John Phinney and George Evans, was originally posted on GARP – Global Association of Risk Professionals on March 10, 2017.
Massive amounts of siloed and unstructured data complicate the huge challenge of managing operational risk in the rapidly growing alternative assets industry. However, advanced data analysis can temper this risk by uncovering the impact of operating model decisions and by detecting complex patterns that are not otherwise readily transparent.
What Does the AlphaGo Analogy Reveal About Detecting Hidden Patterns?
Last year, in a feat that was thought to be impossible not too long ago, an artificial intelligence program created by Google beat an established master at the Chinese board game "Go" for the first time. The program, AlphaGo, did so in part by recognizing and taking advantage of complex patterns in the movement of the stones used by the game's players — patterns that were invisible to its human competitor.
Something similar is happening with efforts to manage operational risk in the alternative asset management industry, which includes hedge funds, private equity, real estate and structured assets. With more than 17,000 registered investment advisors, 58,000 alternative funds and an expected $20 trillion in assets by year-end 2020, the industry is vastly complicated. Moreover, a massive and expanding publicly-accessible digital footprint comprised of ADV filings, vendor relationships and RFPs adds to its complexity.
Indeed, in 2016, alternative asset managers filed 40,000 ADVs — and, what's more, 40% filed more than once (up 28% from 2015). Historically, this data has been mostly siloed and unstructured. Now, however, newer technologies are emerging that can capture this information in a normalized, structured database.
What Is the Payoff From Advanced Data Analysis?
The Data Analysis Payoff
While the data flow can be massive (as much as a terabyte a day), the payoff from providing daily analysis can be significant. As with artificial intelligence and Go, patterns start to emerge that were previously undiscoverable. The data algorithms typically look for change at the margin among factors that include internal valuation, self-administration and qualified audits, for example.
The working thesis behind the expanding use of advanced data analysis is straightforward: complex systems can add risk, and unnecessarily complex systems can add unnecessary risk. A corollary would be that, as an investor or allocator, you want to know that a manager has systems in place that are commensurate with the level of operational risk inherent in the fund.
What Did the Data Reveal About Regulatory Violations and Complexity?
While many of the operational changes flagged by data analysis may not seem especially worrying in isolation, patterns that emerge through such analysis may suggest otherwise. Detection of complex patterns could have, for example, come in handy for the eight percent of alternative asset advisors that incurred a regulatory violation over a recent 36-month period (see Figure 1).
Prior to their regulatory issues surfacing, 80 percent of the regulatory "violators" had a medium or high complexity profile. Of course, provided that systems are in place to manage it properly, a high level of complexity (see Figure 2) isn't an issue in and of itself. Moreover, the patterns discerned by the algorithms are worth knowing, regardless of whether or not they portend a regulatory issue.
In the case of the alternative asset managers that incurred a regulatory violation, identifying these patterns may or may not have saved the day — but it would have at least suggested that a closer look under the hood was in order. These kinds of operational metrics may have been largely invisible in the traditional due diligence process.
What Does This Mean for the Future of Operational Risk Management?
Human beings are geared to detect patterns, but can be quickly overwhelmed by the kinds of massive data now available in the alternative assets space. Fortunately, technology has reached the point where high volume and multiple sources are no longer insurmountable obstacles.
In fact, the measurement of operational risk can now provide significant insight across the entire industry, from allocators to the managers themselves. Like AlphaGo, it's just a matter of seeing what's in front of our eyes in new ways.
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John Phinney and George Evans are co-founders of South Norwalk, CT-based Convergence Inc., which identifies, tracks and reports changes across the alternative asset management industry on a daily basis.
Key Points
What does the AlphaGo analogy illustrate, and why do Phinney and Evans use it?
- AlphaGo detected patterns invisible to a human expert: The piece states AlphaGo, Google's Go-playing AI, won by "recognizing and taking advantage of complex patterns in the movement of the stones... patterns that were invisible to its human competitor."
- This is used as a direct parallel to operational risk detection: The piece states "something similar is happening with efforts to manage operational risk in the alternative asset management industry."
- The analogy frames technology as revealing what was already present, not inventing new information: The piece closes by stating it's "just a matter of seeing what's in front of our eyes in new ways," reinforcing that the data already exists but requires new methods to interpret.
What industry scale and complexity factors does the piece cite as of 2017?
- Specific industry size figures are given directly: "More than 17,000 registered investment advisors, 58,000 alternative funds and an expected $20 trillion in assets by year-end 2020."
- A specific digital footprint is named as a complexity driver: "A massive and expanding publicly-accessible digital footprint comprised of ADV filings, vendor relationships and RFPs adds to its complexity."
- A specific year-over-year filing trend is cited: "In 2016, alternative asset managers filed 40,000 ADVs — and, what's more, 40% filed more than once (up 28% from 2015)."
- Data volume is described as substantial: The piece states data flow "can be massive (as much as a terabyte a day)."
What is the "working thesis" of this piece, and what specific factors does the data algorithm examine?
- The core thesis links complexity directly to risk: "Complex systems can add risk, and unnecessarily complex systems can add unnecessary risk."
- A specific investor-facing corollary is drawn from this thesis: "As an investor or allocator, you want to know that a manager has systems in place that are commensurate with the level of operational risk inherent in the fund."
- Specific factors examined by the data algorithms are named: The piece states algorithms "typically look for change at the margin among factors that include internal valuation, self-administration and qualified audits, for example."
What specific finding does the piece report connecting complexity profiles to regulatory violations?
- A specific violation rate is stated directly: "Eight percent of alternative asset advisors... incurred a regulatory violation over a recent 36-month period."
- A specific pre-violation complexity finding is stated directly: "Prior to their regulatory issues surfacing, 80 percent of the regulatory 'violators' had a medium or high complexity profile."
- The piece explicitly cautions against treating complexity alone as a red flag: "Provided that systems are in place to manage it properly, a high level of complexity... isn't an issue in and of itself."
- The piece frames the finding as a due diligence gap rather than a guaranteed predictor: "Identifying these patterns may or may not have saved the day — but it would have at least suggested that a closer look under the hood was in order," adding that "these kinds of operational metrics may have been largely invisible in the traditional due diligence process."
What conclusion do Phinney and Evans draw about the future of operational risk management?
- Human pattern detection is described as fundamentally limited by data volume: "Human beings are geared to detect patterns, but can be quickly overwhelmed by the kinds of massive data now available in the alternative assets space."
- Technology is described as having overcome this limitation: "Technology has reached the point where high volume and multiple sources are no longer insurmountable obstacles."
- The benefit is framed as extending across the entire industry, not just to one type of user: "The measurement of operational risk can now provide significant insight across the entire industry, from allocators to the managers themselves."
- The authors' own background is presented as direct industry credibility: The piece closes by identifying Phinney and Evans as "co-founders of South Norwalk, CT-based Convergence Inc., which identifies, tracks and reports changes across the alternative asset management industry on a daily basis."