H33-74 for Asset Management

What gets attested in asset management

Each of the following operational events emits an H33-74 proof at the moment it occurs. The collection composes into the operational history that audit, compliance, and regulatory teams reconstruct from.

• Trade decisions: order generation, best execution analysis, allocation.
• NAV calculations and pricing committee determinations.
• Subscription and redemption authorizations including lock-up and gating decisions.
• Pre-trade compliance screens: restricted list, concentration, mandate breach.
• Governance actions: shareholder voting, proxy decisions, board materials.
• Investment committee decisions and rationale.
• Counterparty risk assessments and trading limit changes.

Regulatory pressure that already justifies this

Asset Management is regulated under frameworks whose audit horizons now extend past the lifetime of the systems and vendors holding the evidence. H33-74 produces evidence that survives that horizon:

• SOX. Publicly listed asset managers. See: SOX crosswalk
• DORA. EU asset managers, fund administrators, depositaries. See: DORA crosswalk
• SEC Rule 38a-1 / 206(4)-7. Compliance program documentation for US RIAs and 40 Act funds.
• AIFMD. European alternative investment fund managers.
• MiFID II. Best execution and recordkeeping for European brokers and asset managers.

Scenarios this changes

Tokenized fund migrates from one chain to another

The fund re-issues the on-chain token as normal tokenization work. Every prior subscription, redemption, NAV calculation, governance action, and compliance check carries forward as PQ-signed proofs anchored to the new chain via batched commitment.

SEC inquiry requires evidence of best execution from three years ago

The proof of every order routing decision, execution venue selection, and post-trade analysis is produced. The compliance officer and venue justification are part of each proof.

LP audit requires proof of investment committee decisions

Each IC decision proof includes the voting members, the data reviewed, the model output, the disposition, and any dissents. Verified independently without operator infrastructure.

What survives versus what gets replaced

How to start

Three integration patterns, ordered by how invasive each is.

Pattern 1 — Receipt at the policy engine

The decision system (policy engine, approval workflow, AI scorer) emits an H33-74 proof for every decision at the moment it is made. No change to upstream systems. Auditors verify proofs directly.

Pattern 2 — Receipt at the system of record

Each system of record (treasury, claims, records, EHR) is wrapped so that committed transactions emit H33-74 proofs in addition to the existing audit log. Existing systems remain unchanged. Proofs become a parallel canonical record.

Pattern 3 — Receipt at the integration bus

Service mesh or integration bus intercepts cross-system events and emits H33-74 proofs. Highest reach, requires bus integration. Useful where systems-of-record cannot be modified.

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