Map Delegated Authority Across a Family Office

Write one row for one legal decision

Start with the trust, company, VCC, partnership, foundation, account or individual that owns the decision. Define the action precisely, such as approving an investment, signing a contract, appointing an adviser, making a distribution or releasing a payment. Then identify the document that grants authority. An organisation chart may show reporting lines, but it does not prove who can bind a legal owner or direct a trustee.

Related guidance: VCC for family offices guide

Set thresholds that cannot be split

A threshold should state currency, aggregation period, related transactions, total exposure and whether commitments, guarantees, follow-ons, fees and contingent obligations count. Define when a routine decision becomes reserved because of novelty, conflict, leverage, illiquidity, reputation or a document exception. Prevent transaction splitting by requiring related items to be considered together. Record who interprets an ambiguous threshold and how that interpretation is reviewed.

Related guidance: trustee delegation oversight

Separate decision from operational release

Map the full chain: recommendation, conflict check, formal decision, signature, instruction entry, payment or trade release, independent verification and record completion. One person may perform more than one step only where documents and controls permit it. A bank portal entitlement can be wider than internal policy or narrower than a valid resolution. Treat either mismatch as a control issue, not as evidence that the portal setting decides the legal question.

Design absence and conflict routes

For each row, name a valid substitute or state that the action pauses. Seniority alone does not make a deputy authorised. Record how incapacity, absence, recusal, emergency and a vacant office are handled. A trustee, board, investment committee and family council may have different substitute rules. Test that providers recognise the approved alternate before an incident, and prevent a conflicted person from choosing their own replacement informally.

Related guidance: family office key-person succession control

Reconcile the matrix to live permissions

Inventory bank mandates, custody users, trading systems, accounting approvals, document-signing tools, data rooms and provider contact lists. Compare each entitlement with the current matrix and source document. Remove access that is no longer authorised, add missing dual controls and keep evidence of the change. Reconcile both ways: every matrix authority should have the operational capability it needs, and every live capability should have a current authority source.

Run scenario tests. Use an investment approval, trust distribution, urgent vendor payment, conflicted adviser appointment and absent principal. Ask staff to identify the legal owner, decision authority, signatory, system user, checker, substitute and evidence file. Stop the test when a mismatch appears and record the remediation. A tabletop exercise is useful only when it tests real documents and entitlements rather than an idealised chart.

Version the matrix and preserve superseded copies. Changes in trustees, directors, executives, mandates, banking arrangements, family circumstances and service providers can alter authority. State the effective date and approver for each revision. Notify affected staff and providers through verified channels, then test that old access was removed. A current spreadsheet with no change history cannot prove which authority applied to an earlier action.

Review exceptions and near misses. Repeated requests just above a threshold, informal family instructions, expired mandates, emergency overrides and conflicts reveal where the matrix is unclear or impractical. Update the policy only through the proper authority, not by normalising workarounds. Report material gaps to the relevant trustee, board or principal and keep unresolved rows marked as hold.

Related guidance: VCC roles and responsibilities guide