Article

Investment firms: get paid for your records

By TrustPast

Updated November 7, 2026

This page is for the owners and partners of investment firms: advisers, wealth managers, private equity and venture shops, family offices and small asset managers with a few dozen people. A firm like that has spent years writing down why it bought, held and sold. Most of it sits in an email archive, a CRM and a shared drive nobody opens twice.

The thing most firms don’t know is that the archive they keep for the examiner is also the best record of how the firm decided. Every memo, every follow-up question, every “let’s pass” is in there with a date on it. A buyer pays to license records like these to train AI models. It isn’t buying your positions. It wants the reasoning that produced them.

If you have read our page on what data buyers actually want from a trade business, the idea is the same with different files. A roofer’s estimate chain and an analyst’s diligence trail are both records of judgment, kept while the work happened. Here is what that looks like in an investment firm, what stays out, and how it works with micro1.

The records an investment firm keeps

These are our examples, not a buyer’s list. They are the records a firm of this kind produces as it works, year after year, whether it calls them records or not.

The idea log and the screening note. Someone saw a company, a fund or a theme and wrote three lines about it. Most of those notes end in a pass. The pass is the interesting part: it says what the firm looks for by saying what it rejected.

The diligence file. The question list sent to management. The answers, and the follow-ups when the answers were thin. The expert-call notes. The reference checks. The site visit write-up. The data-room index, with the documents someone flagged.

The investment committee memo. The thesis, the risks, the base and downside cases, the sizing argument. Then the minutes: who pushed back, what was asked for, whether the vote went through or came back for another round. A memo that went to committee twice shows the firm changing its mind in writing.

The financial model and its versions. Not the spreadsheet itself so much as the history of it. Version four cut the growth rate after a customer call. Version six added a covenant test after the lender’s term sheet came in. Each change has a reason, and the reason is usually in an email.

The monitoring record. Quarterly reviews of each holding. Board-meeting notes. The watch list, and the notes that put a name on it or took it off. The exit memo, written when the firm sold, which often says what it got wrong.

The client side. For an adviser or wealth manager, the review meeting notes, the rebalancing rationale, the drafts of the quarterly letter and the edits a partner made to them. The investment policy template and how it changed over the years.

The compliance log. The pre-clearance requests, the review of marketing pieces, the exceptions and how each was settled. It reads like a list of hard cases with the answers attached.

Two of these record types carry most of the trail. The first is the mail. A firm of this kind usually archives every message, because it has to, so its email archives go back further and more completely than almost any other company’s. The second is the pipeline. Our page on CRM records covers what a buyer looks for there: the deal stages, the notes on each call, the reasons a deal was lost.

The value isn’t in any one file. It is in the chain. An idea arrived, got screened, got diligenced, went to committee, was sized, was watched and was sold. A buyer wants to see how each step was decided: which question killed a deal, how a disagreement between two partners got settled, how a holding that went wrong was diagnosed. That is the how, not the who. The names come out; the reasoning stays.

How many years? A firm that has run for a decade has ten years of committee cycles, two or three market regimes and a few hundred decisions with their outcomes. That is the depth a buyer means when it asks about history.

See your estimate

What counts, in micro1’s own words

micro1 publishes what it is looking for. On its data partnerships page it says: “We are looking for data that reflects how work is actually performed within an organization.” It goes on: “This may include standard operating procedures (SOPs), process documentation, internal knowledge bases, workflows, templates, operational frameworks, and other business process artifacts.”

Then it says what matters most: “The most valuable datasets capture real operational expertise, decision-making processes, and repeatable workflows.” An investment firm’s committee process is close to a definition of a decision-making process. It is written down, it repeats every cycle, and each run of it leaves a memo, minutes and a result.

micro1’s page also lists industries whose data “can contribute”. One of them is Finance & accounting, described as “Financial processes, SOPs, reconciliations, approvals, reporting workflows, and operational documentation.” Another is Sales & CRM: “CRM data, sales processes, playbooks, customer lifecycle documentation, and revenue operations.” micro1 doesn’t name investment firms as a category. We apply what it does say: a firm’s approval workflows, its reporting cycle and its pipeline fall under those two headings.

On who is eligible, micro1 says it is “looking for established companies with 30+ full-time employees, mature business operations, and substantial historical operational data.” It names the data: “internal communications, SOPs, project histories, CRM records, support tickets, and other business documentation.” And it adds: “Data should be primarily in English.”

On volume, micro1 says: “There’s no fixed minimum number of files, documents, or terabytes.” Instead, “We evaluate the historical depth, breadth, quality, and relevance of the available data.” And: “Companies with several years of records across multiple business systems are generally a stronger fit.” A firm with an email archive, a CRM and a document system, each going back years, is what that sentence describes.

micro1 doesn’t publish a list of what it won’t take. It says what it wants and leaves the rest to the scoping conversation. That is where the next section matters.

What is never included

Start with the clients. Client names, account numbers, balances, holdings by client, tax identifiers, dates of birth, beneficiary details and anything from a suitability questionnaire are personal data. They are not what a buyer wants, and they stay out. Our page on what is never included shows where those details hide in a company’s files: in signatures, in attachments, in the subject lines of old threads.

An investment firm has more than personal data to think about. It holds information that belongs to other people under contract. A portfolio company’s board pack, a data room’s contents, an expert network’s call transcripts, a co-investor’s financial model and a client’s side letter may all carry confidentiality terms. Anything a client or counterparty owns under contract stays theirs. Our page on client-owned work and NDAs goes through how to find those terms and what to ask before scoping.

Then there are the rules. The SEC’s books-and-records rule for advisers, 17 CFR 275.204-2, requires an adviser to keep “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.” The same rule says most required records are kept “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.” That rule is about keeping records. It doesn’t say whether, or how, a firm may license what it keeps. Ask counsel.

The FTC’s page on the Gramm-Leach-Bliley Act says the Act “requires financial institutions – companies that offer consumers financial products or services like loans, financial or investment advice, or insurance – to explain their information-sharing practices to their customers and to safeguard sensitive data.” If your firm serves individuals, that is another reason the client side stays out, and another reason to ask counsel. Our page on health, payment and other regulated data covers the regulated categories in more detail.

Material non-public information is the last one. Notes from a call that touched on an issuer’s unannounced results, or a watch-list entry tied to a restricted name, need your compliance officer’s view before they go anywhere. This is our own advice, not micro1’s. When in doubt, it stays out.

None of this means the firm has nothing to offer. It means the scope is drawn around the reasoning, the process and the internal debate, with the clients and the counterparties cut out.

How de-identification works

You don’t scrub the files yourself. micro1 says so in plain terms: “Does my company need to anonymize its data before transferring it? No, micro1 has processes for de-identifying and transforming sensitive information.”

micro1 publishes four things it confirms with the company “Before any participation”. One is de-identified before sharing, in micro1’s words: “Personal and identifying information is removed or transformed before your data is shared with third parties.” Another is data segregation: “Your data is kept separate from other companies’ data, with access restricted to authorized personnel.” A third is defined retention periods: “Raw data is deleted according to an agreed schedule.” The fourth is that data is licensed “exclusively to labs and enterprises based in the U.S. and allied countries.”

On what happens after transfer, micro1 says: “Depending on the nature of the data, personally identifiable information may be removed and certain datasets may undergo synthetic rewrites that preserve workflow structure while reducing direct ties to original records.” For an investment firm, that means a committee memo keeps its structure: the thesis, the risks, the questions, the vote. It loses the names of the people and, where the scope says so, the names of the companies discussed.

micro1 also says “companies have the opportunity to review representative samples before use,” and that “deletion requests are honored according to the terms of the engagement.” That sample review is where a compliance officer can check that the client side really is gone. Our page on how de-identification works covers what to look for in a sample and what to ask about the rewrite step.

One point in your favour: a firm that already runs an archive for its regulator knows where its data lives. It can name the systems, the date ranges and the mailboxes that hold client data. That list makes the scope easier to draw.

What decides the price

micro1 publishes three tiers on its data partnerships page. “Qualified Enterprise Data Partnerships” are $100K-500K (indicative, not an offer). “Large-scale operational datasets or ongoing participation across multiple teams and business functions” are $500K-3M (indicative, not an offer). “Highly unique, proprietary operational data” sits in the top tier, $3M+ (indicative, not an offer). micro1 says payments are “typically ranging from $100K to over $3M” (indicative, not an offer).

What moves a firm within those tiers is published too. micro1 says compensation “is based on the quality, uniqueness, and value of the data provided.” In its FAQ it names the factors: “dataset size and volume, workflow complexity, data quality, domain expertise represented, and the uniqueness of the operational knowledge contained within the dataset.” It adds: “Each partnership is evaluated individually.”

Read those factors against an investment firm. Domain expertise is the firm’s whole product. Workflow complexity is high: a single deal can run through a dozen people and several months. Uniqueness depends on the strategy. A firm with a narrow, unusual approach and a long written record of applying it has something few others have.

micro1’s payout page asks three questions: how many employees, how many years of data, and where the company is headquartered. It then says the result is an “Indicative estimate only. Final payout is determined based on data sources, volume, quality, access terms, and due diligence.” Years and headcount are the starting point; how complete the trail is decides the rest.

What lowers the number, in our reading of those factors: a short history, an archive with gaps after a system change, a scope so narrow after the client carve-out that little reasoning is left. What raises it: years of committee memos with outcomes attached, and debates written down rather than held in a room. Our page on what decides the price goes through each factor micro1 names.

On timing, micro1 says: “Once your company transfers its data, micro1 has 30 days to review and approve it.” Then “payment will be made within 30 days of invoicing.”

Which programme fits

micro1’s programme is for companies with 30 or more people, counted now or at peak, and for a company of any size outside the US. micro1 says it is “currently prioritizing US companies, followed by other Western markets,” and that “current demand is strongest for companies based in the United States, United Kingdom, and Canada.” Our estimate asks how many people work at the firm, counting everyone, and names the programme that fits your headcount. Where that line sits is on the programme page for 30 or more people.

A firm that has closed has a route of its own. micro1’s company referral page lists a “Defunct Company Data Partnership” and says: “We are acquiring data from companies that are no longer operating.” Its published requirements are “30+ employees”, “10+ Countries”, “English” and “All industries”, with company compensation of “$100K-$3M+ for approved data packages” (indicative, not an offer). A wound-down fund manager’s archive, kept for the retention period after the doors closed, is the kind of record that route describes. Who can sign for a firm that no longer exists is a question for counsel.

Investment firms share a lot with payments and fintech companies: both run on approvals, both keep regulated customer data out of scope, and both have years of decisions with outcomes attached. They share the incident-and-response habit with cybersecurity companies, where every alert is diagnosed and written up. And they share the long, versioned decision trail with semiconductor and materials companies, where a process change goes through review the way a position goes through committee.

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Questions and answers

Does micro1 want our client account data?

No. micro1 says it is “looking for data that reflects how work is actually performed within an organization,” and that personal and identifying information “is removed or transformed before your data is shared with third parties.” Client accounts, balances and identities stay out of scope, as our own advice.

We keep our email for the examiner. Can the same archive be licensed?

Possibly. Ask counsel before anything else: the SEC’s books-and-records rule for advisers, 17 CFR 275.204-2, covers written communications about advice given, and what you may share from an archive kept under it is a legal question, not one we answer.

How small can the firm be?

micro1’s published line is “30+ full-time employees,” and it says it is “currently prioritizing US companies, followed by other Western markets.” A firm outside the US goes to micro1 at any size under our one-buyer rule; micro1 decides at application.

How much does micro1 pay?

micro1’s data partnerships page lists tiers of $100K-500K, $500K-3M and $3M+ (indicative, not an offer). micro1 says compensation is based on “the quality, uniqueness, and value of the data provided.”

Do we have to clean the files first?

No. micro1 says: “No, micro1 has processes for de-identifying and transforming sensitive information.” What helps is a written list of where client data sits, so the scope can leave it out.

Do we keep ownership of our research?

micro1 says: “Companies retain ownership of their underlying data.” The firm keeps its archive, its financial models and its CRM, and keeps working in them.