Reserve evidence and attestation: what the decision maker looks at
The decision maker checks four things in the reserve file: whether ledger and custody statements share the same reference date, whether the valuation method is stated and applied consistently, whether the attestation carries an independent signature, and whether the currency mix matches what holders were told. A file missing any of the four goes back before review starts.
What changes once the file is under review
Reserve evidence is not read once. It is read against the previous submission, against the disclosure given to holders, and against whatever the reviewing team already holds on file from earlier contact. A number that moved without explanation draws a question before anything else in the file does.
There is a point after which the file stops being a draft. Once the reviewing team marks it complete and opens the substantive stage, any change to a figure, a custodian, or a valuation method restarts the clock rather than amending it in place. Firms that treat the file as final too early lose weeks correcting one line.
Timing also shifts once a request for additional information goes out. The response window is set by the reviewing team, not by the issuer, and a late or partial answer is treated the same as no answer for scheduling purposes.
What the decision maker checks, item by item
| What the file must show | Why it is checked |
|---|---|
| Ledger and statement on the same reference date | A gap in dates hides a gap in holdings |
| Valuation method named and applied the same way as last time | An undisclosed change in method can mask a shortfall |
| Attester independent from the issuer's own finance function | A self-signed attestation carries no evidential weight |
| Currency and asset split matching public disclosure | Holders rely on the disclosed split, not the internal one |
| Custody chain traceable to a named account | An unnamed intermediary breaks the chain of evidence |
| Prior submission attached for comparison | Movement without explanation is treated as unresolved |
How to build the file
- The finance lead pulls the ledger and the custodian statement for the same reference date, not the closest available date.
- The compliance officer confirms the valuation method matches the previous filing or documents the change with a reason.
- An independent party signs the attestation; a person inside the issuer's own finance chain cannot sign it.
- The compliance officer checks the currency and asset split in the file against the public disclosure text, line by line.
- Counsel reviews the custody chain for named accounts and flags any intermediary without a named counterparty.
- The file owner attaches the prior submission and marks any changed figure with a one-line explanation.
Who decides, and on what timeline
The reviewing team assigns a single case handler once the file is logged. The case handler decides whether the file is complete; an incomplete file is returned with a list of gaps rather than queried piece by piece.
Once complete, the file moves to substantive review, where the case handler can escalate an open question to a senior reviewer. The senior reviewer's sign-off, not the case handler's, closes the file. Response windows for any request are set out in the request itself and run from the date of receipt, not the date of drafting.
Common branches
If reserves sit with more than one custodian, the file needs a statement from each one dated to the same reference point, not a combined summary drafted afterwards.
If the attestation is older than the reviewing team's stated freshness window, it is treated as expired evidence, and a new one is requested before anything else proceeds.
If the valuation method changed between filings without a stated reason, the file is treated as incomplete even where every number is otherwise correct.
What this page does not cover
This page describes the file and the review sequence. It does not size the reserve, does not set the valuation method, and does not draft the attestation letter itself.
Where the question is a counterparty that changed its name mid-file, the Counterparty report when the counterparty changes name sets out what that costs to get wrong.
Where an assignment inside the custody chain is unsigned, the Document report when an assignment is unsigned covers who decides and when.
Where reserves sit across more than one jurisdiction and a dispute becomes possible, the Jurisdiction report before choosing where to sue covers that separately.
Verified
This page reflects file-handling practice observed across reserve evidence submissions, last checked at publication. It does not cite external legal texts, since the procedure described here is internal to the reviewing team rather than set out article by article. How our team collects, cross-checks and dates the underlying material is set out separately in the Methodology: collection, cross-checking and dating explained.
Related reading: Notification to the supervisor step by step covers the stage that usually precedes reserve review.
FAQ
How long does reserve evidence and attestation take in practice?
The completeness check happens within days of the file being logged. Substantive review runs longer and depends on how many requests for additional information go out; each one runs its own response window rather than shortening the overall timeline.
Which documents are needed to start?
A dated ledger, a matching custodian or bank statement for the same date, a signed independent attestation, and the prior submission for comparison. Anything missing from this set means the file is returned before review starts.
What happens if the other side does not respond?
A missed response window is treated the same as a negative answer for scheduling purposes. The file does not advance, and the case handler notes the gap rather than chasing it indefinitely.
If a file has already stalled and an on-site inspection has been raised as a possibility, When an on-site inspection is announced in practice sets out what that step tends to cost when it is handled poorly.