File 08Governance

How decisions are made.

Riffington is operated as a codified underwriting business. Acquisition authority, override authority, and doctrine integrity are governed by named instruments and reviewed on a fixed cadence. The summary below is the public-facing portion of the firm's governance file.

Item 01

Investment Committee

Every acquisition above the firm's standing delegated authority is approved by the Investment Committee. The Committee is composed of the firm's principals together with the Chief Risk Officer and external maritime counsel. Membership and quorum rules are disclosed under NDA.

Item 02

Underwriting doctrine

Pricing follows a codified underwriting doctrine — invoice-compliance review under 46 CFR Part 541 and applicable foreign tariffs, debtor-class matrix, jurisdictional posture, age and documentation grading. Departures from the matrix require a written exception memo and Committee sign-off.

Item 03

Override authority

Authority to depart from the underwriting matrix is hierarchical and named. Routine exceptions are signed off by the CRO; structural exceptions require the full Committee; matrix overrides require unanimous Committee plus the Chief Executive. No single individual can approve a price above standing limits without an audit trail.

Item 04

Doctrine integrity audit

The firm runs a monthly Doctrine Integrity Report — walk-rate, exception rate, concentration drift, post-mortem references, creeping-normalization watch. Two consecutive months of drift on any reading triggers a written explanation; three consecutive months trigger an instrument review.

Item 05

Post-mortem library

Every closed file produces a post-mortem entry: base-case versus realized recovery, doctrine implications, vocabulary tags. New underwriters read the library before clearing their first solo file. The library is read at quarterly calibration.

Item 06

Independent review

Annual independent review of underwriting files is performed by external counsel against the doctrine of record. The review covers a sampled vintage and reports to the Committee.