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Fund Administration: Who Keeps the Books and Records

Fund administration is the record keeping behind a pooled arrangement: striking the value of what is held, reconciling the cash and the securities against the books, working out what each cost comes to, and producing the statements that go out. A party paid a rate on a value should not be the party that computes it, so the record keeping is kept apart from the investment decisions on purpose.

One number does nearly all the work in this business, and it is the value of what is held. The charge a manager earns is a rate applied to it. An investor's statement shows a share of that value. An investor pays going in and receives coming out on amounts worked out from the same value. A single number carrying that much weight does not appear by itself. Somebody computes that value, from a written policy, on prices that arrive from outside, and who that somebody is turns out not to be an administrative detail at all.

Everything below runs on one invented manager, Vaidehi Asset Managers Limited, which looks after assets under managementThe total value of everything a manager looks after for other people, added up. A manager's charge is applied to this total, and the total moves with the market whether the manager does anything or not. of Rs 1,80,000 crore.

What does fund administration actually do?

The job title says nothing; the tasks do. There are five, and the shape they make is the whole argument for splitting the work up.

The first task is keeping the books of the arrangement: a written record of every holding, every cost and every movement of money in and out. The second is striking the value of what is held, on a stated policy, using prices that arrive from outside. The third is reconciliationChecking two records that were kept by different parties, from different inputs, against each other, and then investigating every difference rather than picking whichever record seems more trustworthy.. Every cycle, what the books say is checked against what the party holding the securities says and against what the bank says, and every difference is investigated instead of a side being chosen. The fourth is working out what each cost comes to and when it is taken, an accrualRecognising a cost or an income in the period it belongs to, rather than in the period the money actually moves. How that recognition is done is covered separately. question rather than a payment question. The fifth is producing the statements and the reports that go out to investors and to the authority.

Look at those five tasks together: not one of them is a decision about what to hold. Nothing on that list picks a security, sizes a position, or changes what the arrangement is exposed to. Every single task is a record of a decision somebody else already took, or a check on a record, or a report of a record. That absence is not an accident and not a limitation. The absence is the definition of fund administration.

Five tasks, and one column that reads the same way every time THE TASK IS IT A DECISION ABOUT WHAT TO HOLD? Keeping the books of the arrangement No Striking the value of what is held, on a stated policy No Reconciling the books against two outside records No Working out what each cost comes to, and when No Producing the statements and the reports No Deciding what to hold, which is the one task that changes the outcome, sits with the manager instead The column reads No five times, and the one Yes is drawn outside the list on purpose
Every task inside fund administration is a record, a check on a record or a report of a record, and the one task that changes what an arrangement is exposed to sits with the manager rather than inside this list.
Try it out

Which one of these is not part of fund administration?

Four parties sit around one pot of money in an arrangement like this, and each of them holds a different piece of the job. The manager decides what is held. One party has the securities and the cash themselves. Another writes down what is held and what it is worth. A fourth keeps the record of which investor holds how much. Splitting the work four ways is inconvenient and expensive, and it is done anyway. The alternative is one party deciding, holding, valuing and recording all at once, with nobody outside it able to check any of the four.

One pot of money, four parties, and one job each THE POOLED ARRANGEMENT THE MANAGER decides what is held THE CUSTODIAN holds the securities and cash THE ADMINISTRATOR writes down what it is worth THE REGISTER KEEPER records who holds how much No box on this drawing carries two of the four jobs, and that is the entire design
The manager decides what is held, one party holds it, another writes down what it is worth and a fourth records which investor holds how much, and the point of four parties is that no single one of them decides, holds, values and records at the same time.
Try it out

Pick one before the next section gives it away. A manager is paid a rate on the value of what it holds for other people. Who should compute that value?

Why does this work sit with somebody who is not making the investment decisions?

Here is the reason the function has a name of its own rather than being a department inside the manager. The manager is paid a rate on the value of what is held. Vaidehi Asset Managers Limited charges a blended 0.55 per cent of assets under management, and assets under management stand at Rs 1,80,000 crore, so the charge for the year works out at Rs 990 crore. Run that multiplication yourself and watch what it depends on. Every rupee of that Rs 990 crore is a rate applied to a value. If the value moves, the revenue moves with it, and nothing the manager did caused either.

So the principle is as plain as it can be made: the party paid on a value does not strike the value. Not because anybody is suspected of anything. The check is worth having whether or not a single person would ever act on the interest, and that is the part worth holding on to. A control is not an accusation.

The same arrangement is accepted everywhere else without a second thought. Nobody lets the vegetable seller hold the scales in one hand and read the weight out from memory, and the scales sitting on the counter where the buyer can see the dial too is no reflection on the seller. The visible dial is what makes the transaction easy for both of them. The seller does not have to be trusted. The seller therefore does not have to spend anything on being trusted. An arrangement makes the same trade when the computing of a value goes to a party who is not paid on the answer.

The same work, drawn as one box and then as two ONE BOX DOING BOTH JOBS COMPUTES THE VALUE and is paid a rate on that same value its own output feeds its own income, and nobody outside the box can check either an interest in its own answer THE SAME WORK, SPLIT IN TWO PAID A RATE ON THE VALUE COMPUTES THE VALUE the lower box earns nothing that depends on whether the answer is high or low no interest in its own answer
Drawn as one box, a party that both computes the value of what is held and is paid a rate on that value has an interest in its own output, which is the reason the computing sits somewhere else.

Who holds the securities, and is that the same party that keeps the books?

No, and a reader who merges those two has lost the reason there are two parties at all. One party has the securities and the cash themselves and can move neither without an instruction. Custody is that job. A different party writes down what is held, what it is worth and what has moved. Administration is that job. One has the things; the other has the description of the things.

The split looks like duplication. Two sets of records of the same holdings, kept in two places, at two costs, and somebody has to check them against each other every cycle. Why would anybody set it up like that deliberately?

Because the reconciliation between two records means something only when the two records were kept by different parties working from different inputs. That is the whole return on the duplication, and it is easy to miss. Two records kept inside one party agree by construction. Both records were built from the same source, by the same people, on the same system, and when they agree they have established nothing that was not already known. Agreement is evidence only when disagreement was genuinely possible.

A household makes the same point. Two people share the month's spending and one of them keeps the notebook, writing every entry twice, once on a running list and once on a summary list. At the end of the month the two lists agree. Of course they do. Now change it so that each person keeps their own record from their own receipts, and at the end of the month the two records agree. Two independent chances for that agreement to fail went by, and it took neither. The agreement is worth something.

Two jobs that sound alike and are not the same job CUSTODY Has the securities themselves Has the cash itself Moves neither without an instruction holds the thing ADMINISTRATION Writes down what is held Writes down what it is worth Writes down what has moved holds the description Checking one against the other counts only because two parties built the two records
Custody holds the securities and the cash, administration writes down what is held and what it is worth, and two records kept inside one party would agree by construction and prove nothing.
Try it out

Two records of the same holdings are kept inside one party, and they agree perfectly. What has that agreement established?

So what does a check between two parties actually look like to somebody sitting in front of one? Two records are laid beside each other, line by line. Most lines match. One does not. The drawing below is that moment. The single line that does not match is what matters in it, not how many lines were laid out beside it.

What a check between two parties looks like on the day it fails THE BOOKS, KEPT BY THE ADMINISTRATOR THE RECORD, KEPT BY THE PARTY HOLDING IT a security holding the same security holding = a second security holding the same second holding = a cash balance the same cash balance = an entitlement from a corporate event nothing on this line at all x A DIFFERENCE, NOT YET EXPLAINED The next move is to find out why, not to pick whichever record looks more likely to be right
Two records from two parties are laid side by side, three lines agree and one does not, and the difference on the fourth line is left unexplained here because investigating it rather than choosing a side is the whole of the work.
Try it out

A check throws up one line where the two records disagree. What is the correct next step?

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What does an ordinary day look like, and why is the order the control?

Nothing about this work is dramatic. The work is the same sequence, in the same order, every cycle, and the order is doing more work than any single step in it.

First, prices arrive from outside, along with news of any corporate eventSomething a company does that changes what a holding is worth or how much of it there is, such as a split, a bonus issue or a payment to holders. affecting a holding. Second, the holdings on the books are checked against the record kept by the party holding them, and the cash on the books is checked against the bank. Third, the value of what is held is struck on the stated policy, and any holding without a price that other people arrived at goes down a route the policy already describes rather than being decided in the moment. Fourth, the costs belonging to the period are accrued. Fifth, the value is checked and released. Sixth, the statements and the reports go out.

Every one of those checks happens before the value is released, and that ordering is the entire control. A value that goes out and is corrected the next morning has already been used. Somebody bought at it, somebody sold at it, and a correction repairs the record without repairing either of those transactions. The bell cannot be un-rung. Most ordinary work is arranged as check afterwards and fix if needed, and arranging this work the same way would be cheaper. A value that has already been used rules it out.

An ordinary cycle, in order, with the point of no return marked prices and events arrive 1 holdings and cash checked 2 value struck on the policy 3 costs for the period accrued 4 checked and released 5 statements and reports out 6 THE POINT OF RELEASE left of the marker: a mistake found here costs the time it takes to fix it right of the marker: a mistake found here has already been acted on by somebody Which is why all five checks are crowded to the left of one dashed line
Prices arrive, holdings and cash are reconciled, the value is struck on the stated policy, costs are accrued, the value is checked and released and the statements go out, in that order, because every check after the release is a check on a number somebody has already used.
Try it out

A value is released, investors buy and sell at it that day, and it is corrected the next morning. Who carries the difference?

Whose money, whose decision, whose risk, and who is paid regardless?

Four questions get asked of every party in this business, and the administrator answers them in a pattern that no other party matches. Take them one at a time.

Whose money is it? The investor's, and the administrator never holds a rupee of it. Whose decision is it? Not the administrator's, on anything that moves the outcome. Whose risk is it? The investor's for the value going up or down, and the administrator's for whether the number is right. And who is paid regardless of what the value does? The administrator, on a basis unconnected to whether the value went up.

The last pair is the finding: the administrator is the only party whose pay is disconnected from the outcome and from the decision at once, and that disconnection is exactly what makes it usable as a check on both. The manager is paid on the size of the money. An investor lives with the result. Only the administrator is positioned so that a higher value earns it nothing extra and a lower one costs it nothing, and a party with no stake in the direction of a number is a party that can be asked to compute it.

The four questions, and the column that answers them differently THE INVESTOR THE MANAGER THE ADMINISTRATOR Whose money is it? theirs not theirs never held at all Whose decision is it? whether to be here what is held none that moves it Whose risk is it? the value falling losing the mandate the number being wrong Paid on what? pays rather than paid the size of the money nothing tied to it Two rows separate the last column from both others: the decision and what the pay is tied to
The administrator never holds the money, makes no decision that moves the outcome and is paid on a basis unconnected to the value, which is the combination that lets it act as a check on the party that does all three.
Try it out

Of the four questions, which two does the administrator answer differently from the manager?

Where does the cost of this work sit, and who ends up bearing it?

The work is paid for either out of the manager's own cost line or by the arrangement itself, and which of those two it is decides who ends up bearing it. The general point goes no further than that without reaching for a figure.

Now the specific, and it starts with an absence rather than a number. Vaidehi Asset Managers Limited reports one cost line of Rs 594 crore for the year, with no split of it whatsoever, so what share of that line the administration and custody of anything comes to cannot be said. Not roughly, not as a range, not as a plausible-sounding fraction. No split of the Rs 594 crore appears in the reported figure.

The whole Rs 594 crore can be worked against two different bases, and it is worth working. Against revenue, Rs 594 crore over the Rs 990 crore of revenue is 60.0 per cent of revenue. The remainder is an operating marginWhat is left of revenue once the cost of running the business is taken out, stated as a share of that revenue. Settled separately and used here rather than rebuilt. of Rs 396 crore, or 40.0 per cent of revenue. Against the value being looked after, the same Rs 594 crore over assets under management of Rs 1,80,000 crore is 0.33 per cent of assets under management. One cost line of Rs 594 crore, two bases, two entirely different-looking numbers, and both of them correct. Say the base out loud every time or neither figure is portable.

One cost line of Rs 594 crore, read against two different bases BASE ONE: REVENUE OF Rs 990 crore revenue Rs 990 crore less the cost line Rs 594 crore 60.0 per cent of revenue operating profit Rs 396 crore 40.0 per cent of revenue BASE TWO: ASSETS UNDER MANAGEMENT OF Rs 1,80,000 crore, on a scale from 0 to 1.00 per cent 0 0.33 per cent 1.00 per cent 0.33 per cent of assets under management, with no part of it split out here
Vaidehi Asset Managers Limited's costs of Rs 594 crore are 60.0 per cent of its Rs 990 crore of revenue and 0.33 per cent of assets under management of Rs 1,80,000 crore, and the administration and custody sit inside that one line as a part this record does not split out.
Try it out

Take the same Rs 594 crore. One denominator turns it into 60.0 per cent, a different denominator turns it into 0.33 per cent. Which is which?

Try it out

An analyst wants to know what administration costs this manager. Vaidehi Asset Managers Limited reports costs of Rs 594 crore for the year. What can be said?

Using it

What does somebody outside the arrangement actually do with this?

An analyst reading a manager's accounts does two things with all this and nothing more ambitious. The first is to look for the split. If a manager publishes what it pays for administration and custody separately from what it pays its own people, the analyst can see how much of the cost line is contracted out to somebody else and how much is carried inside, and those two behave very differently when the value being looked after falls. A cost that is a rate on a value falls with the value. A cost that is a salary does not.

The second is to ask who strikes the value and who holds the securities, by name, and treat the answer as part of the description of the arrangement rather than as trivia. An investor can do the same thing from the other side without reading a single account. Ask three questions of any arrangement before putting money into it: who computes the value, on what written policy, and what happens to a holding nobody else is trading. All three answers are published rather than secret, and asking for them is ordinary rather than suspicious. The person on the other end of the call has answered them many times before.

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What goes wrong when this work is done badly, and who finds out last?

Four things, and none of them looks dramatic while it is happening. A value struck on a stale price, where the number used was true yesterday and is not true today. A holding that exists on the books and not at the party holding it, or the reverse. A cost accrued in the wrong period, so one set of investors quietly carries a charge that belongs to another set. And a holding with no observable priceA price arrived at by other people trading the same thing, rather than one worked out from a model or from somebody's judgement. valued on a route nobody wrote down in advance.

The failure: reading a published value as something observed rather than something computed

The wrong reading treats the value of what is held as a fact of nature, like a temperature on a thermometer. The only question left worth asking is then whether it went up. An investor reading a statement and an analyst reading a disclosed figure both make the mistake, and both make it for the same reason: they are looking at a single number with no working behind it, and a number with no working behind it looks like a measurement.

The reading misses that a value is struck on prices that arrive from outside, on a valuation policyThe written statement of how the value of each kind of holding is arrived at. The contents of that policy, and who approves it, are settled by the authority named in the table below. somebody wrote, by a party somebody appointed, and each of those three is a choice made by a person. Where a holding has an observable price the choices hardly show. The price everybody else is trading at does most of the work. Where a holding has no observable price, the choices are the number.

The cost: an investor who buys or sells at a value carries every choice inside it, and the investors who stay carry the difference whenever a value is corrected afterwards. So here is the move rather than a warning: ask who strikes the value, on what policy, and what happens to a holding with no observable price. Those answers are published. Not one of them requires anybody to reveal anything. Nothing on any statement invites the question, so an investor who has never asked has not failed at anything either.

Where the written policy hardly shows, and where it is the whole number A HOLDING WITH AN OBSERVABLE PRICE THE PRICE OTHERS TRADED AT arrives from outside, and does the work the written policy, barely visible here two careful parties would land on much the same figure A HOLDING WITH NO OBSERVABLE PRICE nothing arrives from outside THE WRITTEN POLICY is the entire content of the number which is why it is written before it is needed rather than when it is The policy matters least where it can be checked and most where it cannot
Where a holding has an observable price the valuation policy hardly shows, and where it has none the policy is the value, which is why the policy is written before it is needed rather than in the moment it is.

And who finds out last? The investor. Every one of those four failures is internal to parties the investor never deals with, and the only thing that reaches the investor is the released number itself, with no working attached and no way to rebuild it. The investor is not being careless. The structure does it: a single figure travels outward while everything that produced it stays inside.

A value struck on yesterday's price is wrong today. See who finds out last.

Which of these conditions is somebody else's to set?

Four of the things walked past above belong to somebody else to decide. Not the manager, and not any party in the drawings above. An authority settles each one, revises it whenever it needs to, and publishes the wording that currently applies. A copied answer becomes simply incorrect rather than merely elderly, and elderly is the better of the two to be working from. Each row below therefore carries the authority where the answer would otherwise sit.

India

Which four answers does an authority keep, and why?

What is setThe value hereWho sets it
The conditions on which an administrator and a custodian are registeredNot stated herethe Securities and Exchange Board of India (SEBI) at sebi.gov.in
What records are kept behind an arrangement, in what form, and for how longNot stated hereSEBI at sebi.gov.in
The policy under which the value of a holding is struck, and who approves itNot stated hereSEBI at sebi.gov.in
What is reported to the authority, and how oftenNot stated hereSEBI at sebi.gov.in

All four of those move, and whoever is named alongside a row keeps that row's answer current. A written-down answer does not merely age on the day it changes, it turns false, and false is far harder for a reader to catch than old.

Try it out

Last one. Name the one thing a valuation policy is written to handle before it is needed.

The work behind an arrangement is one subject and the arrangement itself is another. What a pooled arrangement is, how the value of a holding is struck each day and which day's price an order gets are all covered separately. The register of which investor holds how much, and how a holding moves from one person to another, is covered separately. What a holder pays as a share of the value of their holding is covered separately. How a charge accrued across a period is recognised as revenue belongs to the Institute of Chartered Accountants of India at icai.org. Who may be registered to do this work, what records are kept and for how long, what a valuation policy must contain and who approves it, and what is reported to the authority all belong to SEBI at sebi.gov.in.

Who decides the four things left open?

AuthorityWhy it is named hereSiteChecked
SEBIThe conditions on which a custodian and an administrator are registered.sebi.gov.in23 August 2026
SEBIWhat records are kept behind an arrangement, in what form, and for how long. No form and no period appears here.sebi.gov.in23 August 2026
SEBIThe policy under which the value of a holding is struck, and who approves it.sebi.gov.in23 August 2026
SEBIWhat is reported to the authority, and how often.sebi.gov.in23 August 2026
Institute of Chartered Accountants of IndiaNamed once, for when a charge accrued across a period is recognised as revenue.icai.org23 August 2026
Association of Mutual Funds in India (AMFI)Named for where an aggregate of the value managed across the industry would be published. No aggregate is reproduced here.amfiindia.com23 August 2026

Vaidehi Asset Managers Limited is invented.
Educational material. Not advice on any investment, tax, budget or market position.

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