Article
Hedge funds and quant firms: get paid for your records
Updated
This page is for the chief operating officer, the general counsel or the founder of a hedge fund, a quantitative trading firm or a systematic investment manager. You have a research team, a trading desk, an operations group and a compliance function. If the firm is a registered adviser, you also have something most companies don’t: a time-stamped archive of written communications, kept because the SEC’s books-and-records rule requires it.
That archive is the thing a fund usually doesn’t think of as an asset. It was built for an examiner, not for a buyer. But read it the other way. It holds years of research notes, committee debates, risk reviews, operational breaks and the email behind each one. A buyer pays to license records like these to train AI models, and what it wants from them is how decisions were made, not what was traded.
We explain the general principle in what data buyers want from a trade business. The examples there are roofers’ estimates and plumbers’ job notes, and the principle travels well: the value is in the reasoning written down while the work happened. This page applies it to a fund, with micro1 as the buyer.
The records a hedge fund keeps
These are our examples, not a buyer’s list. They are what a fund or a quant firm produces in the ordinary course of running money.
The research note. An analyst writes up an idea: the thesis, the evidence, the risks, what would prove it wrong. A portfolio manager writes back. The note gets revised, shelved, revived a year later. A discretionary fund has thousands of these. The ones that were rejected say as much about the firm’s judgement as the ones that were funded.
The investment committee memo. For a larger position, a memo goes to committee. The minutes record who raised which concern and how it was answered. Over ten years, the committee file is a record of how the firm weighed risk against conviction.
The research log in a quant shop. A hypothesis, a backtest, a result, a note that the result didn’t survive transaction costs. Then the next hypothesis. Most of the work in a systematic firm is failed tests, and the good ones log why each one failed. The code review around the research code belongs to this record too.
The model change log. When a production model changes, the firm writes it down: what changed, why, who approved it, what was monitored after. It is change control for a strategy.
The risk report and the limit breach. Daily risk numbers, and the email when a limit was hit. The breach note says what happened, who was told, and what was done about it. That is a diagnosis written in real time.
The operations trail. Trade breaks, reconciliation differences, a failed settlement, a pricing error on an illiquid position. Each has a ticket or a thread that shows how operations found the cause and fixed it.
The compliance file. Policies, the code of ethics, personal trading pre-clearance, the review of a marketing document before it went out, the annual review of the compliance programme.
The archived email. If the firm archives its email, the archive holds the conversation behind every record above: the analyst asking a data vendor about a revision, the operations lead chasing a prime broker, the compliance officer asking a trader to explain a message. Our page on email archives shows where the useful threads sit in a company inbox.
The archived chat. If the firm captures its messaging as well, that archive holds the rest: the desk channel, the research channel, the channel where an outage was handled at the open. Our page on chat archives in Slack and Teams explains which channels carry reasoning and which carry noise.
Taken together, those records show how a fund actually works. How an idea became a position, or didn’t. How a backtest became a model and how the model changed. How a break was traced to its cause. The how, not the who, and a fund has written more of it down than almost any company its size.
See your estimateWhat counts, in the buyer’s own words
micro1 states its eligibility on the data partnerships page: “We’re looking for established companies with 30+ full-time employees, mature business operations, and substantial historical operational data.” The examples follow: “This can include internal communications, SOPs, project histories, CRM records, support tickets, and other business documentation.”
micro1 doesn’t name hedge funds or quant firms as a category. Its page does say “Operational data from every industry can contribute”, and its referral page lists “All industries” among the company requirements. The closest example it gives is “Finance & accounting”, described as “Financial processes, SOPs, reconciliations, approvals, reporting workflows, and operational documentation.” A fund’s operations group lives inside that sentence. Reconciliations and approvals are what it does all day.
Another example fits the compliance function: “Legal & contracts”, described as “Policies, contract workflows, review processes, governance documentation, and compliance procedures.”
On what it values most, micro1 says: “We are looking for data that reflects how work is actually performed within an organization.” And: “The most valuable datasets capture real operational expertise, decision-making processes, and repeatable workflows”. The committee memo is a decision-making process. The model change log is a repeatable workflow. The research note is operational expertise, signed by the person who has it.
One more line from the same page applies to a fund’s files: “There’s no fixed minimum number of files, documents, or terabytes.” As our own reading, a small research team with a deep archive isn’t ruled out by the size of its files alone.
Note what micro1 doesn’t say. It doesn’t ask for positions, signals, holdings or returns. Its pages describe the process of work. As our own reading, that is where a fund’s records fit best: the process that produced the trades, not the trades.
What is never included
Investors’ names, their account details, subscription documents, tax forms, bank and payment details, and the personal details of your staff are not what a buyer pays for. Our page on what is never included shows where those hide in a company’s files.
micro1 doesn’t publish a list of records it excludes. As our own advice, a fund has four kinds of record to keep back or to raise first.
Live strategy. Anything that would let a reader reconstruct a current signal, a current book or a current execution method. That is the firm’s edge, and it is the firm’s call whether any of it is in scope.
Material nonpublic information. Research files and chat archives can carry it, from an expert call or a conversation with a company. It stays out, and counsel decides where the line is.
Regulated and client-owned records. Investor records sit under their own rules, and managed account agreements or side letters may say who owns what. Our pages on health, payment and other regulated data and client-owned work and NDAs go through where those records hide and how to keep them out.
The archive’s own rule. The SEC’s Rule 204-2, in 17 CFR 275.204-2, applies to “Every investment adviser registered or required to be registered under section 203 of the Act”. Among the records it lists are “Originals of all written communications received and copies of all written communications sent by such investment adviser relating to” matters including “Any recommendation made or proposed to be made and any advice given or proposed to be given”. It says most of its records “shall be maintained and preserved in an easily accessible place for a period of not less than five years from the end of the fiscal year during which the last entry was made on such record, the first two years in an appropriate office of the investment adviser.” For a registered adviser, that rule is why the archive exists. It doesn’t tell you what else may be done with copies of it, and we can’t either. Ask counsel before any archived record moves.
How de-identification works
micro1 doesn’t ask the firm to redact anything first. Its page asks “Does my company need to anonymize its data before transferring it?” and answers: “No, micro1 has processes for de-identifying and transforming sensitive information.”
micro1 lists four confirmations made “Before any participation”. The first, “U.S. and allied buyers only”, reads: “Your data is licensed exclusively to labs and enterprises based in the U.S. and allied countries.” The second, “Data segregation”: “Your data is kept separate from other companies’ data, with access restricted to authorized personnel.” The third, “De-identified before sharing”: “Personal and identifying information is removed or transformed before your data is shared with third parties.” The fourth, “Defined retention periods”: “Raw data is deleted according to an agreed schedule.”
The protections continue on the data partnerships page. Data is “processed through isolated pipelines that prevent it from being commingled with other engagements.” Staff with access “use company-managed devices and follow established security controls and training requirements.” Some datasets “may undergo synthetic rewrites that preserve workflow structure while reducing direct ties to original records.” And “Upon request or at the end of an engagement, data is deleted according to the agreed retention and deletion terms.”
For a fund, the line to hold on to is the sample review. micro1 says companies “are given the opportunity to review representative samples before prepared data is used.” That is where your compliance officer checks that no investor, counterparty or ticker that matters survived. The full process is on how de-identification works.
What decides the price
micro1 publishes three tiers. The first, $100K-500K, is for “Qualified Enterprise Data Partnerships” (indicative, not an offer). The second, $500K-3M, is for “Large-scale operational datasets or ongoing participation across multiple teams and business functions” (indicative, not an offer). The third, $3M+, is for “Highly unique, proprietary operational data” (indicative, not an offer).
The factors, in micro1’s words: “dataset size and volume, workflow complexity, data quality, domain expertise represented, and the uniqueness of the operational knowledge contained within the dataset.” On its estimate page: “Final payout is determined based on data sources, volume, quality, access terms, and due diligence.”
As our own reading, a fund scores in an unusual pattern.
Domain expertise is high. A risk review written by a portfolio manager and challenged by a chief risk officer is expert reasoning in its plainest form. Workflow complexity is high too: research, trading, risk, operations and compliance hand work to each other every day.
Quality is where the archive helps. A firm that captured all its email and chat for compliance has a more complete trail than most companies ever keep. The gaps are usually phone calls and meetings, so the memo written afterwards matters.
Access terms and due diligence will weigh heavily, because of the limits above. A firm that settles early which records are in scope, and has counsel sign off, makes the review shorter.
On years, micro1 says “Companies with several years of records across multiple business systems are generally a stronger fit.” Each factor is on what decides the price. micro1 evaluates each partnership individually, so a tier is a published range, not an offer.
Which programme fits
Our rule sends companies with 30 or more people, now or at peak, to micro1, and companies of any size outside the US. micro1’s published line is “30+ full-time employees”. Count everyone, including the operations and technology staff. A US firm below the line has a different programme; the estimate asks for your headcount and names the one that fits. How the line is counted is on the programme page for 30 or more people.
Funds close too. micro1’s referral page describes a “Defunct Company Data Partnership” with the line “We are acquiring data from companies that are no longer operating.” It lists “30+ employees”, “10+ Countries”, “English” and “All industries” as requirements, with company compensation of “$100K-$3M+ for approved data packages” (indicative, not an offer). For a closed fund, who controls the archive and who can sign for the entity come first. Our page on closed companies starts there.
Related categories
Chemistry and materials science R&D runs on the same loop as a quant research team: a hypothesis, a test, a failed result, a logged reason. Call centers and BPO keep a regulated archive too when they run outbound telemarketing, of scripts and call records, and face the same question about what those copies may be used for. And biotech and life sciences labs keep the closest thing to a model change log outside finance: change control on every procedure.
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Questions and answers
Does micro1 want our positions or our signals?
micro1 doesn't say. Its pages describe data that reflects how work is actually performed within an organization, such as SOPs, process documentation and internal communications. As our own advice, anything that would give away a live strategy or nonpublic information stays out until counsel has read it.
Can we license email we archived for the SEC?
We can't answer that. The SEC's Rule 204-2 decides which communications a registered adviser keeps and for how long; what else may be done with those copies is a question to ask counsel before anything moves.
Do investors' names go to micro1?
micro1 says personal and identifying information is removed or transformed before data is shared with third parties. As our own advice, investor records, subscription documents and account details stay out entirely.
We have fewer than 30 people. Does that rule us out?
micro1 publishes that it is looking for established companies with 30 or more full-time employees. A US firm under that line has a different programme, and our estimate names the one that fits your headcount.
What does micro1 pay?
micro1's data partnerships page lists three tiers, $100K-500K, $500K-3M and $3M+ (indicative, not an offer). It says each partnership is evaluated individually.
Who sees the data?
micro1 says access is restricted to a limited number of authorized team members, and that data is licensed exclusively to labs and enterprises based in the U.S. and allied countries.
*Purchases are made by micro1 under its data partnership programme. TrustPast is an independent referral partner of micro1.
Sources
- micro1, data partnerships: eligibility, the data it looks for, the finance example, the four steps, the tiers, privacy and ownership (micro1.ai)
- micro1, refer a company: the Enterprise and Defunct Company Data Partnerships, their requirements and company compensation (micro1.ai)
- micro1, how much is your data worth: the indicative estimate, what the final payout is based on, the four confirmations (micro1.ai)
- eCFR, 17 CFR 275.204-2 (SEC, books and records to be maintained by investment advisers): written communications and retention periods