Five Disciplines. One Mandate: Accountability
Custodia Advisory — What We Do
Private equity firms operate with a clear obligation to their investors: every cost drawn from the fund must be justified, managed, and scrutinised with the same discipline applied to the investment portfolio itself. Legal spend rarely receives that scrutiny — and the gap between what's billed and what should be billed is, in our experience, consistently larger than firms expect.
Custodia Advisory works with private equity and asset management institutions to close that gap. That means auditing invoice histories to identify non-compliant and recoverable spend, building and enforcing Outside Counsel Guidelines that reflect current market standards, and training the procurement and finance teams who receive invoices day to day to review, challenge, and escalate billing with consistency and confidence.
The margin is already there. We help you claim it.
Our Services
1. OCG Enforcement
Outside Counsel Guidelines exist to set the terms on which external law firms bill your institution — rate structures, staffing levels, permitted disbursements, billing formats, prior-approval requirements. Most institutions have a well-drafted OCG. Few have a way of checking, invoice by invoice, whether firms are actually complying with it.
We review billing against your OCG line by line, identify where firms have drifted from agreed terms, and put in place the enforcement mechanism that was missing — so the guideline stops being a document and starts being a control.
What this typically uncovers:
Rate increases applied without the required prior notice or approval
Staffing above agreed seniority levels for routine matters
Disbursements and third-party costs billed outside agreed categories
Block billing and vague time entries that obscure what was actually done
2. Legal Spend Audits
A legal spend audit is a structured review of invoices, matters, and billing patterns over a defined period — designed to answer one question: is this institution paying for what it agreed to pay for, and nothing more.
We work directly with your existing invoice data (no new systems required), identify discrepancies against engagement letters, OCGs, and fee arrangements, and produce a clear, evidence-based report you can act on — whether that means recovering fees, renegotiating terms, or changing which firms you instruct.
Scope can include:
Single-matter or single-firm audits
Portfolio-wide reviews across multiple law firms and jurisdictions
Historical audits (recovering overbilling from prior periods)
Ongoing periodic audits as a standing control
3. Procurement Training & Invoice Controls
Most billing problems aren't caught at the law firm. They're caught — or missed — at procurement, the moment an invoice lands for approval.
We train procurement and finance teams to recognise the guideline breaches that actually matter: block billing, unauthorised rate increases, duplicate charges, and scope creep dressed up as additional work. Just as importantly, we build the habit of following through — querying, rejecting, and holding firms accountable at the point of invoice receipt, before a bad bill becomes a paid one.
Training covers:
Recognising common OCG breach patterns at first read
Practical escalation: what to query, what to reject, and how
Building internal confidence to challenge external counsel
Embedding invoice review as a standing discipline, not a one-off exercise
4. Dormant Entity Reviews
Dormant entities don't stop costing money just because they've stopped doing business. Registered office fees, government filing fees, annual returns, and director fees keep accruing long after a structure has outlived its original purpose — often unnoticed, because no one owns the question of whether the entity should still exist.
We run quarterly reviews of dormant entities across your structure, flagging which ones are still earning their keep and which ones are quietly draining fees for no operational reason — giving you a clear basis to decide what to keep, wind down, or consolidate.
What this typically delivers:
A full inventory of dormant and low-activity entities across the structure
Cost analysis — what each entity is costing annually to maintain
Recommendations on dissolution, consolidation, or continued retention
A standing quarterly review cycle to prevent the problem recurring
5. Fiduciary Oversight
For institutions that answer to investors, trustees, or other principals, every dollar of legal and operational spend is, in some sense, someone else's money. Fiduciary oversight is the layer that ensures spend decisions can withstand scrutiny — from auditors, from investors, and from regulators.
We help build and run the oversight processes that demonstrate this discipline: documented approval trails, periodic independent review, and clear escalation paths when something falls outside agreed parameters.
This work typically supports:
Investor and LP reporting on cost governance
Audit readiness for legal and operational spend
Internal policy development for spend approval and escalation
Independent, periodic review separate from day-to-day procurement