Your fund admin, your custodian, and your sub-advisor all keep their own books. The NAV is only as good as their agreement. Milemarker automates the reconciliation continuously.

NAV reconciliation is the daily process of matching the fund administrator's books of record — positions, transactions, pricing, cash, and corporate actions — against the custodian's records and the sub-advisor's trading records before the fund strikes NAV under Rule 22c-1's forward pricing requirement. Mismatches between the three books produce breaks. Breaks resolved after strike become as-of corrections, pricing adjustments, and — at the materiality threshold — NAV errors that trigger reimbursement analysis and board-level disclosure. A parallel "shadow NAV" is sometimes calculated independently by the sponsor as a check on the admin's strike.

The NAV Reconciliation Problem

The NAV strikes every business day at 4 p.m. ET. Between the close and the strike, the fund administrator's books, the custodian's positions and transactions, and the sub-advisor's trade records need to agree on what the fund owns, at what price, and what cash moved. In practice, they often don't — and the breaks are usually discovered after the NAV is already out the door.

The evidence lives in three places. The fund admin's books sit in the admin's system (Ultimus, SEI, ALPS, SS&C, BNY Mellon, State Street). The custodian's positions and cash sit at the custodian. The sub-advisor's trades sit on the sub-advisor's blotter, which may not hit the admin's system until the next morning. Reconciling them today is often a spreadsheet-based exercise emailed between fund ops, sub-advisor ops, and the admin's account manager.

Pricing exceptions — stale prices, fair value determinations under Rule 2a-5 — live in PDFs attached to daily email from the admin. As-of transactions, when a trade posts retroactively, create breaks on prior days that ripple forward. Dividend record dates, corporate actions, and fair value hits are applied on different timing by admin, custodian, and sub-advisor, producing breaks that look structural but are really timing.

When a break stays uncorrected and moves NAV by more than the firm's materiality threshold — typically 0.5% of NAV — the firm enters NAV error territory: reimbursement analysis across affected shareholders, board-level disclosure, and an audit trail that has to be reassembled from email, spreadsheets, and broker statements. This is exactly the kind of incident where the evidence was always theoretically available but never actually assembled.

What Automated NAV Reconciliation Requires

01

Three-Way Reconciliation

Fund admin, custodian, and sub-advisor books compared continuously — positions, transactions, cash, and pricing — not once a day in a spreadsheet the morning after.

02

Pre-Strike Exception Flagging

Breaks surfaced before 4 p.m., not after. Fund ops and sub-advisor ops see the same exception list, with severity and ownership already assigned.

03

Pricing & Fair Value Log

Daily pricing, stale price events, and fair value determinations joined to the holdings and trades they affect, with lineage back to the fund admin's source feed.

04

Corporate Action Alignment

Splits, dividends, mergers, and spin-offs normalized across admin, custodian, and sub-advisor so timing mismatches are explainable rather than mysterious.

05

As-Of Transaction Tracking

Retroactive trades that rewrite prior-day books are surfaced immediately with their downstream NAV impact already calculated.

06

Shadow NAV Calculation

Optional independent NAV calculation on the firm's own data as a control against the admin's official strike — useful for larger complexes and CFO oversight.

How Milemarker Automates It

Milemarker ingests daily feeds from the three books that need to agree. Fund admin positions, transactions, pricing, fair value log, and corporate action records come in from Ultimus, SEI, ALPS, SS&C, BNY Mellon, or State Street. Custodian positions, transactions, and cash balances come in from the custodian of record. Sub-advisor trade blotters come in via SFTP, OMS integration, or file drop — whichever the sub-advisor supports.

Everything is normalized into a single security master keyed on CUSIP, ISIN, and SEDOL so the same security is the same record across all three sources. Accounts, portfolios, and fund share classes map to a unified hierarchy. Corporate actions, dividends, and fair value events become first-class records with effective dates — not footnotes on a spreadsheet.

Break detection runs continuously throughout the day. Positions that don't match, cash that doesn't tie, trades that appear on one blotter but not another, and prices that diverge beyond threshold all surface in one exception view that fund ops, sub-advisor ops, and the admin's account team can see at the same time. Severity, ownership, and SLA are assigned automatically.

Navigator AI investigates breaks in plain English. "Why is our XYZ cost basis different from the admin's?" "What's the history of fair value events on this security over the last 90 days?" "Which trades posted as-of more than five business days late last quarter?" Answers come from the firm's Snowflake warehouse with full lineage, which means every finding has source evidence behind it.

Milemarker Relay automates the routing. When a break is detected, it goes to the right operations owner with a 2-hour resolution SLA, the underlying detail already attached. When a NAV error crosses the materiality threshold, the reimbursement analysis workflow kicks off from assembled evidence — not a forensic pull three days later.

Before Milemarker

Breaks discovered the morning after strike

Spreadsheets emailed between admin, sub-advisor, and ops

Fair value determinations in PDFs

As-of trades rewrite prior days with no alert

NAV errors reassembled from email trail

No independent shadow NAV check

With Milemarker

Breaks flagged before strike

One shared exception view across parties

Fair value log queryable with the holdings

As-of impact calculated automatically

NAV error workflow from assembled evidence

Shadow NAV as an independent control

Who This Is For

Fund Operations Teams

The fund ops team running daily reconciliation between the admin and the sub-advisor is the first beneficiary. Work that was spreadsheet-based, email-driven, and after-the-fact becomes continuous, queryable, and pre-strike. The people doing the hardest daily work in the fund complex get the most immediate lift.

Fund Accounting Leaders

The head of fund accounting — often a director or VP overseeing the admin relationship and the firm's NAV integrity — needs visibility across every break and every as-of adjustment. A unified reconciliation data layer provides that view continuously, not just in the monthly operating committee slide.

CFOs Overseeing Fund Administration

CFOs at fund sponsors — including firms like Flat Iron Wealth that run proprietary '40 Act funds alongside an RIA — need oversight of admin performance without being the one reconciling. Milemarker gives the CFO a structural view of break volume, resolution SLA, and admin service quality without adding headcount to the middle office.

Sub-Advised Fund Sponsors

Sponsors of sub-advised funds face the full three-way reconciliation challenge by definition. When the portfolio is traded somewhere outside the sponsor, the data gap is structural. Milemarker closes it without replacing the sub-advisor's trading desk — the sub-advisor keeps trading, the sponsor gets the visibility.

Frequently Asked Questions

Does Milemarker calculate NAV?

No. Milemarker does not strike NAV. The fund administrator is the official book of record. Milemarker automates the reconciliation around the NAV process — three-way matching against custodian and sub-advisor books, pre-strike exception detection, and shadow NAV calculation if the firm wants an independent check.

Do you replace the fund administrator?

No. The fund admin continues to own fund accounting, NAV striking, financial statements, and regulatory reporting. Milemarker ingests the admin's books and normalizes them alongside custodian and sub-advisor records so the firm has continuous visibility into breaks and exceptions.

What fund admins do you integrate with?

Milemarker integrates with the major '40 Act fund administrators — Ultimus, SEI, ALPS, SS&C, BNY Mellon, State Street — via SFTP, API, or data feed. The integration pulls positions, transactions, pricing, fair value determinations, dividend records, and corporate action data into the firm's Snowflake warehouse.

How do you handle corporate actions?

Corporate actions — splits, dividends, mergers, spin-offs — are one of the most common sources of NAV breaks because fund admin, custodian, and sub-advisor apply them on different timing. Milemarker normalizes corporate action events into a single model with effective dates, so timing mismatches surface as explainable rather than mysterious.

What about fair value determinations?

Fair value events are logged by the fund administrator under Rule 2a-5 and the firm's Valuation Committee policies. Milemarker ingests the fair value log alongside the daily pricing data so variances, fair value hits, and their downstream NAV impact are queryable in one place — useful both for operations and for the CCO's board reporting.

How are NAV errors tracked?

When a break crosses the firm's NAV error threshold (typically 0.5% of NAV or the firm's internal materiality), Milemarker surfaces the affected shareholders, transactions, and as-of dates automatically. The reimbursement analysis starts from assembled evidence rather than a forensic pull, and the full incident is logged for the board and the auditor.

What's the implementation timeline?

Most fund complexes have fund admin, custodian, and one sub-advisor feed flowing within 2-4 weeks. Full three-way reconciliation across all sub-advisors and complete break workflow typically takes 6-10 weeks, depending on the number of sub-advisors and the complexity of corporate action and fair value handling.

Related guides

Part of the Automation & Relay series:

• Data Platform for '40 Act Fund Sponsors: Unifying Fund Admin, Transfer Agent, Sub-Advisor & Custodian Data

• Fund Accounting Data Platform for '40 Act Fund Sponsors

• '40 Act Fund Compliance Data: Rule 38a-1, 17j-1, 22c-1 in One Data Platform

• Sub-Advisor Data Aggregation for '40 Act Fund Sponsors

• N-PORT Reporting Automation: Streamline Quarterly Form N-PORT Filings

• Milemarker Relay for VPs of Technology