Independent Assessment Report

Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians

 

CEFEX Investment Advisor Certification

 

 

Investment Advisor Definition

 

A fiduciary who is responsible for managing a client’s overall investment strategy, which may include deciding on the client’s asset allocation, developing the client’s investment strategy, implementing the strategy with appropriate Investment Managers, and monitoring the strategy, on a one-time or ongoing basis. The term refers to those who provide specific or comprehensive investment advice including financial advisors, broker-consultants, investment consultants, wealth managers, financial consultants trust officers, financial planners and fiduciary advisers.

 

SECTION 1 – COMPANY INFORMATION
CEFEX File No.:	CFX10688
Company Name:	Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians
Address:	2872 Mission Dr.,    Shelbyville   MI   49344-9580   US
Phone:

 

SECTION 2 – ASSESSMENT DETAILS
Date of Registration:	2022.06.21
Assessment Number:	R3
Assessment Team:

Position	Name	Company
Analyst	Matt Boyle	CEFEX
Analyst	Todd Early Analyst	Sovereign Analyst
Client	Thomas Comer	Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians

 

CEFEX Registration Committee (CRC)

The CEFEX Registration Committee is responsible for ensuring the consistency, impartiality and technical merit of CEFEX assessments. Members of the CRC may include: Blaine F. Aikin, CFP®, CFA, AIFA® founder and principal Fiduciary Insights, David A. Vriesenga, Senior Partner Vriesport Consulting Services, Roger Levy, AIFA®, Managing Director Cambridge Fiduciary Services LLC and Carlos Panksep, Vice President, CEFEX.

Attestation

The Analyst is independent of the registered firm. He/she has not been employed or compensated by the registered firm for a period of at least 2 years prior and 6 months following this assessment, for the purposes of providing fiduciary consulting services. The Analyst is an Accredited Investment Fiduciary Analyst (AIFA®) and has the adequate expertise and proficiency to perform this assessment.

Purpose and Scope of this Assessment:

To evaluate the Advisor’s conformance to the practices and associated criteria as defined in the document “Prudent Practices for Investment Advisors” (the Standard) for the declared scope of registration. A full copy of the Standard which is the basis for this assessment, can be found in the Prudent Practices Handbook here.

The scope of registration is as follows:

Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians diversified institutional investment portfolios managed by Sovereign Investment Advisors.

Summary of Assessment Methodology:

The assessment requires that the Analyst plan and perform a review of a representative sample of the Advisor’s written records, interviews with appropriate personnel and, on a test basis, collect evidence supporting the actions taken by the Advisor in providing services to its clients. Sampling of records was conducted in accordance with the statistical guidelines used by the International Organization for Standardization, which requires a maximum sample size equal to the square root of the total available records.

Assessment elements include:

• Background check (performed at initial assessment), including ADV, FINRA BrokerCheck (if applicable) and civil lawsuit databases.
• Document review including Investment Policy Statement, Investment Committee minutes, client performance reports, RFP’s in the selection of service providers, written evidence of Investment Manager reviews, and service agreements.
• Comparison of capital market inputs for asset allocation model assumptions to a benchmark
• Comparison of risk and return models to a benchmark
• Comparison of investment due diligence screens to a standard threshold
• Review of actual investments using a standard fiduciary scoring system. The Fiduciary Score is a measure of an investment’s position relative to a group of peers, using factors such as track record, assets, management tenure, style consistency, etc. over a period of three years.
• Review of arrangements with custodians, brokers and other service providers.

 

SECTION 3 - ASSESSMENT FINDINGS

 

The following Practices were assessed within the 3 months prior to the Date of Registration shown above and found to be in conformity.

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No.	Practice	Status

SECTION 4 - ASSESSMENT CONCLUSIONS AND RECOMMENDATION

 

Based on the findings obtained during the Assessment, the Company is in substantial conformity to the Standard, and is recommended for CEFEX registration.

This assessment has been reviewed by the CEFEX Registration Committee to maintain impartiality and consistency in the registration process. For details on the complete assessment process, please visit www.fi360.com/cefex.

 

Note to Report

The information contained in this report is a summary of an assessment conducted by CEFEX, Centre for Fiduciary Excellence and is valid for 1 year from the Date of Registration shown. The report is suitable for public distribution at the discretion of the certified firm. For any questions related to this report, please contact CEFEX at cefexadmin@broadridge.com.

 

CEFEX, Centre for Fiduciary Excellence is an independent certification organization, and is part of Broadridge Retirement and Workplace. CEFEX works closely with industry experts to provide comprehensive assessment programs to improve the fiduciary practices of investment stewards, advisors, recordkeepers, administrators and managers.
Broadridge Retirement and Workplace offers fiduciary education, training and technology solutions, and helps financial intermediaries use prudent fiduciary practices to profitably gather, grow and protect investors’ assets. Since 1999, the firm has provided financial professionals with the tools necessary to act as a fiduciary in their work with investors. Broadridge Retirement and Workplace is also the home of the Accredited Investment Fiduciary® (AIF®) designation, the Fiduciary Focus Toolkit™ and the Fi360 Fiduciary Score®.