Explain the basic requirements for claiming GIPS compliance, including how the firm is defined and how it defines discretion
The idea
The first decision is how the firm is defined: it must be the entity held out to the public, such as an independent adviser or distinct business unit, and that definition fixes total firm assets, which include every portfolio, discretionary or not. Compliance is firm-wide and all-or-nothing: the firm must meet every applicable requirement, follow the law where it conflicts and disclose the conflict, avoid false or misleading information, and document its policies and procedures. It must present at least five years of compliant history, or since inception, building to ten. It must also define discretion, the ability to implement the intended strategy, because every actual, fee-paying, discretionary segregated account must sit in at least one composite. Partial compliance cannot be claimed.
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- Discuss what the GIPS standards aim to achieve, whom they cover, and how they help investment managers as well as prospective clients and investors
- Discuss the GIPS rules for calculating returns, covering how fees and expenses, cash and cash equivalents, and external cash flows are treated
- Explain the valuation hierarchy that the GIPS standards recommend
- Explain the GIPS rules for calculating composite returns, including the permitted ways of asset-weighting the returns of member portfolios
- Explain what makes a portfolio discretionary for composite construction and, from a set of facts, judge whether a given portfolio is likely to qualify
- Explain how composites are defined around a shared mandate, objective or strategy, and why this matters
- Explain the GIPS composite construction rules, covering when portfolios may move between composites, when new portfolios must be added and when terminated ones must be removed
- Explain what the GIPS standards require in presenting and reporting performance
- Explain when a new or acquiring firm may link to, or show as its own history, the performance record of a prior firm or affiliation
- Discuss why firms seek GIPS verification, what it covers and how it is carried out