The Framework: A Preview of What a Properly Built OCG Actually Covers
Custodia Advisory | Private Equity | Outside Counsel Guidelines
Most Outside Counsel Guidelines in circulation today were drafted once, years ago, and never meaningfully revisited. They cover the basics — rates, general billing expectations, a payment term — and stop there. What they don't cover is usually where the real cost sits: the fine print of how invoices are structured, what counts as a legitimate charge, and what a provider is quietly allowed to bill for simply because nobody ever told them they couldn't.
Custodia has spent considerable time building out a comprehensive billing and invoicing framework — one that goes substantially further than the guidelines most platforms are currently operating under. We're not going to give away the full document here. But it's worth showing a glimpse of what's inside it, because the gap between what most OCGs currently say and what they actually should say is larger than most managers realise.
A flavour of what's covered
Fee structure. A properly built framework doesn't leave pricing open-ended. Fixed fees, agreed at the outset and held for the life of the engagement, are the starting point — not a rate card that quietly escalates every renewal.
What can't be charged. There's a specific, deliberately drawn list of charges that should never appear on an invoice — categories of cost that providers routinely bill for today simply because no client has ever pushed back. Hard disbursements, express fees, and open-ended out-of-pocket categories all belong on that list.
How invoices must be structured. This is where most guidelines are thinnest, and where our framework goes considerably deeper — down to how entities are billed individually, what counts as an unacceptable "summary statement," and the level of line-item detail required before an invoice is even payable.
Onboarding fees on new fund vehicles. A properly negotiated framework closes a gap almost no standard OCG currently addresses — what a fiduciary provider is and isn't entitled to charge when a platform stands up a new entity under an existing relationship.
What counts as overhead, and what doesn't. Administration, clerical work, and general overhead are not billable professional services — but very few guidelines say so explicitly, or define the categories clearly enough for a provider to have no room to argue otherwise.
There's more to it than this — considerably more — but this gives a sense of the shape.
Why we're not publishing the whole thing
The full framework is detailed, specific, and deliberately built to close the gaps that generic templates leave open. That level of detail is exactly what makes it work — and exactly why it isn't something we publish freely. It's built into the engagements we run with clients, refined against real billing practices we've reviewed across multiple jurisdictions, and tailored to the platform it's being applied to.
If your current OCG reads like the thin version — rates and a payment term, and not much else — that's usually the clearest sign it's due for a proper rebuild.
Custodia Advisory builds and enforces comprehensive OCG frameworks for private equity and alternative asset managers. Enquire about a complimentary review of your current guidelines.