Free private markets document template
Data & Reporting Policy Template
Draft a private markets data and reporting policy covering ownership, valuation, performance metrics, data quality, access and retention.
01
Purpose
This policy establishes private markets data and reporting standards for Institutional Investment Office effective July 1, 2027.
02
Scope
The policy covers private equity, venture capital, private credit, real assets, secondaries and co-investments, including fund, manager, cash-flow, valuation, performance and look-through exposure data.
03
Ownership & stewardship
Head of Private Markets is accountable for business definitions and reporting use. Investment Operations Director administers data operations, quality controls and issue resolution.
04
Authoritative sources
Authoritative sources are manager notices and reports, custodian records, audited statements and approved portfolio platform. Every material value should retain source, period, currency, status and update timestamp.
05
Valuation data
Use latest approved manager NAV; document stale values, overrides and material post-period events
06
Performance standards
Required metrics are net IRR, gross IRR where available, TVPI, DPI, RVPI, PME, cash flows and peer-vintage comparisons. Methodologies, cash-flow timing, currency treatment and benchmark versions must be documented.
07
Reporting calendar
Monthly cash-flow close, quarterly portfolio reporting and annual audited reconciliation
08
Data quality
Apply completeness checks, cash reconciliation, variance thresholds, duplicate detection and source-document review. Material exceptions require ownership, target resolution date and documented approval.
09
Access & security
Role-based access with least privilege, quarterly entitlement review and auditable exports
10
Third-party providers
Contractual confidentiality, data portability, breach notification and annual control review
11
Retention
Retain records according to: Permanent investment records; seven years for working files after disposition. Legal holds and regulatory requirements supersede routine disposal schedules.
12
Data incidents
Log, assess, correct, notify affected owners and preserve an audit trail
13
Policy review
Annual review by Investments, Operations, Finance, Risk and Information Security