Independent Assessment Report
Match-E-Be-Nash-She-Wish Band of Pottawatomi Indians
CEFEX Investment Steward Certification
Investment Steward Definition
An Investment Steward is a person who has the legal responsibility for managing investment decisions, including plan sponsors, trustees, and investment committee members.
SECTION 1 – COMPANY INFORMATION |
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| 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 |
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| Date of Registration: | 2025.06.21 |
| Assessment Number: | R6 |
| Assessment Team: | |
| Position | Name | Company |
|---|---|---|
| Analyst | Todd Early Analyst | Sovereign Analyst |
| Analyst | Thomas Welsh Jr | CEFEX |
| 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 Steward’s conformance to the practices and associated criteria as defined in the document “Prudent Practices for Investment Stewards” (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.
Show All Details Hide All Details Show All Substantiations Hide All Substantiations
| No. | Practice | Status |
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| 1.4 | The investment steward identifies material conflicts of interest and avoids or manages conflicts in a manner consistent with the duty of loyalty. Show Detail Hide Detail Show Substantiation Hide Substantiation | Conformity |
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Detail 1.4.4 Conflicts of interest that are not avoided must be disclosed. |
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Substantiation
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| 1.5 | The investment steward requires agreements with service providers to be in writing and consistent with fiduciary obligations. Show Detail Hide Detail Show Substantiation Hide Substantiation | Conformity |
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Detail 1.5.2 The investment steward must evaluate all material compensation, affiliations, and the fiduciary status of each service provider. |
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Substantiation
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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®.
