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Investment performance and GIPS compliance have never been this easy

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GIPS compliance and investment performance can feel overwhelming - but not with us.
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Hear from the firms we’ve helped transform. Our clients value our expertise, reliability, and commitment to excellence in GIPS compliance and investment performance.
“Longs Peak has been instrumental in supporting our commitment to delivering customized wealth management solutions. Their specialized expertise enhances our ability to focus on clients' unique financial needs while maintaining operation efficiency. This partnership allows us to deliver the high level of personalized service that Beese Fulmer is known for.”
Ryan Fulmer
President at Beese Fulmer Private Wealth Management
"Sean and his team's expertise and guidance made our initial GIPS compliance in 2015 seamless and our ongoing compliance and annual verification like clockwork. Longs Peak gives us peace of mind when it comes to GIPS compliance. Thank you for being on top of things and keeping us on track!"
Jennifer Olson
CFA, CFP, CIPM, AIF, CFO at Apriem Advisors
"Longs Peak is a trusted partner that has consistently helped us maintain our GIPS composites and coordinate our annual verification process. In addition, they never hesitate to provide guidance around best practices, educate us on process improvements, and share industry insights and marketing best practices.”
Michael Pearson
Chief Compliance Officer at Balentine Wealth Advisors
“Since the beginning of our partnership, I have relied on Longs Peak to expedite and shepherd our verification. They have been instrumental in our GIPS Verification for the past four and a half years. I am very grateful to have their assistance. We wouldn't be able to maintain compliance without them.”
Meredith West
IT Consultant

Insights and Updates from Industry Experts

Stay informed with the latest information on the GIPS standards and investment performance.

Most managers assume that losing an allocation comes down to returns. Underperform the benchmark, underperform peers, and the mandate goes elsewhere. That happens, but it's not usually the reason a manager gets cut from a search after the numbers already looked competitive.

More often, it's something in how the performance was presented that made an allocator hesitate. A number that didn't match across two documents. A risk statistic nobody could explain. A question in due diligence that the manager couldn't answer cleanly. None of these are calculation errors. They're trust problems, and trust is what allocators are ultimately seeking when they write a check.

Here are the performance problems we see that cost managers allocations most often, and none of them start with the returns themselves.

The Numbers Don't Match Across Documents

An allocator pulls up your factsheet, your pitchbook, and your GIPS® Composite Report, and the composite's five-year return isn't quite the same in all three. Maybe it's a rounding difference, or the factsheet reflects a different "as of" date. The allocator doesn't know that, and they aren't going to assume the best. Inconsistency reads as carelessness, and carelessness in performance reporting raises an obvious question: what else isn't being checked?

This is why we push firms to treat marketing and GIPS compliance as one coordinated process rather than two departments working from different source files. Every document that leaves the building should trace back to the same underlying data.

This matters even more now that due diligence itself is being automated. Operational due diligence teams and consultants are increasingly running AI tools that cross-check pitchbooks, factsheets, DDQs, and regulatory filings against each other, flagging contradictions that used to slip through manual review. A rounding difference or a stale figure that a person might have missed a few years ago is exactly the kind of inconsistency these tools are built to catch instantly. Clean, consistent marketing materials aren't just good practice anymore — they're what it takes to pass a review that may happen before a person ever looks at your numbers.

Performance That Looks Selected, Not Reported

Showing your best-performing account, your best-performing period, or a composite with an unusually small number of accounts invites the question every allocator is trained to ask: what am I not being shown? Due diligence teams know that everyone can't be top quartile. The SEC Marketing Rule's anti-cherry-picking provisions exist because this pattern is common enough that regulators built rules around it, and sophisticated allocators are watching for it. If your performance can be read as overly flattering rather than representative, assume a diligence team will read it that way.

Wanting to lead with your best numbers is an understandable impulse. But diligence teams are trained specifically to spot it, and selective disclosure, even when every number in it is accurate, tends to read as a bigger warning sign than an honest, complete track record would. The stronger story is discipline: the periods where you held to your stated mandate and didn't deviate even while returns lagged. That's a harder story to tell than "we outperformed," but it's the one that actually holds up, because it shows you didn't drift toward whatever was working elsewhere just to keep pace. Chasing returns outside your stated process isn't skill, it's strategy drift, and allocators are trained to spot that just as readily as cherry-picked out performance.

Our advice: resist the instinct to lead with your best examples, and show the scenarios that build trust instead. We recommend showing the ones that demonstrate you stuck to your stated mandate, policies, and procedures, especially when the outcome wasn't your best quarter. Discipline under pressure is a more durable credential than a strong one-off time period, and it's the kind of evidence that holds up long after that number is forgotten.

Statistics You Show But Can't Explain

A page full of risk statistics doesn't build confidence on its own. It invites a follow-up question, and if the manager can't explain what a downside capture ratio of 85% says about the decisions actually made in the portfolio, the statistic becomes a liability instead of an asset. Allocators aren't just checking whether the numbers are favorable. They're checking whether the manager understands their own portfolio well enough to explain it. Statistics presented without interpretation signal that the second answer is “no.”

Likewise, a page of portfolio characteristics that have nothing to do with how the strategy is actually run are not doing you any favors. If you're not making decisions at the sector level, a sector breakdown doesn't tell an allocator anything about your process. If you don't manage individual position sizing, a top-ten holdings list is not adding value.

Your factsheet should be a roadmap for the conversation you want to have, not a checklist of everything other managers include. Every number on it should be something you can explain: how it got there, what decision it reflects, and what it says about how you manage money. A statistic that's only there because everyone else shows it likely isn't helping you if it doesn’t demonstrate active decision making. It's inviting a question you may not have a good answer to.

It's the same logic as a good resume. One padded with every certification, hobby, and unrelated past role doesn't read as impressive, it reads as overwhelming and maybe irrelevant, and it makes the reader work harder to find what actually matters to the job at hand. A factsheet works the same way. The strongest ones include only what's relevant to the case being made and make it easy to connect every line back to it.

No One Can Explain Why a Decision Was Made

This is the one that costs managers the most, and it's rarely about the numbers at all. An allocator asks why a composite was redefined, why a benchmark changed, or why a particular account was excluded, and the answer is a shrug or "that's how we've always done it." Undocumented decisions create the impression that performance is being managed reactively rather than governed intentionally. Firms that can point to a clear, contemporaneous record of why a judgment call was made close that conversation quickly. Firms that can't do this will leave the allocator wondering what other judgment calls haven't been documented either.

The Common Thread

None of these problems are really about whether the strategy performed well. It comes down to whether the story behind the numbers holds up consistently under scrutiny. Allocators aren't just buying returns. They're also buying confidence that what they're being shown today will still be true, and still explainable, a year from now.

The fix isn't more disclosure for its own sake. It's making sure everything across your performance reporting tells the same, well-documented story before an allocator ever has the chance to ask why it doesn't.

GIPS® is a registered trademark owned by CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein.

Mission-driven institutions are entrusted with something larger than capital. They are entrusted with purpose.

Endowments, foundations, and long-term investment pools exist to support education, healthcare, research, environmental initiatives, religious or cultural programs, community development, and countless other causes—often for generations.

That long-term horizon changes how investment performance should be reported. Because when an institution thinks in decades instead of quarters, investment performance is not just about what happened recently, itis about whether the portfolio is structured to sustain spending, preserve purchasing power, and remain aligned with its mission through full market cycles.

Many institutions rely entirely on their investment managers to calculate and present investment performance. That’s common, but it’s not always sufficient.

Performance Oversight Is Not the Same as Performance Results

Investment managers are responsible for generating returns. Boards and oversight committees are responsible for evaluating those results.

Those responsibilities are distinct.

Oversight is a fiduciary duty. It is not passive, and it cannot rely solely on the information created by the party being evaluated. Effective oversight requires independence, consistency, and clarity.

When the same party both manages assets and determines how performance is calculated and presented, the lines between management and oversight can blur—even when intentions are sound and calculations are technically accurate.

In some situations, reporting may not be:

  • Consistent across managers
  • Based on uniform calculation methodologies
  • Presented in a format designed for governance review
  • Structured to facilitate long-term policy evaluation

Consider a board reviewing results from three different managers. Each reports strong performance, but one calculates returns net-of-fees, another presents gross results, and a third uses slightly different valuation timing.

At first glance, the numbers appear comparable. In reality, they may not be measuring the same thing.

Some larger institutions maintain internal performance teams or engage independent performance professionals to standardize reporting, organize data across managers, and present results in accordance with established best practices—often aligning reporting with their Investment Policy Statement and/or recognized frameworks such as the Global Investment Performance Standards (GIPS® standards).

But many of these organizations operate lean. They may not have dedicated performance measurement expertise or the infrastructure required to consolidate, normalize, and present results in a governance-ready format.

In those cases, boards are often reviewing manager-produced materials that were designed primarily for client communication—not institutional oversight. Performance reporting for these institutions should be designed to serve the governing body—not simply to showcase results.

Why This Matters for Mission-Based Institutions

Boards of endowments and foundations are often composed of dedicated volunteers, philanthropists, community leaders, and subject-matter experts. They bring vision, experience, and commitment to the institution’s mission—but not always a deep understanding of investment management and reporting.

That makes investment performance clarity essential. When reporting is unclear, oversight weakens—not because trustees lack commitment, but because the information is not presented in a way that supports meaningful evaluation.

When reporting is structured and tied directly to policy benchmarks, risk parameters, and spending objectives, trustees know what questions to ask. Conversations remain focused on long-term sustainability and mission impact.

A Practical Framework for Strong Performance Reporting

Boards of mission-driven institutions are often operating at the governance-level and should evaluate their reporting structure against four questions:

1. Is performance calculated independently?

Independent calculation or oversight reduces potential conflicts and strengthens fiduciary governance. In institutional investing, separating portfolio management from performance oversight is widely viewed as a best practice.

2. Is the methodology consistent across managers?

Multi-manager portfolios require uniform return calculation, fee treatment, and valuation policies to ensure comparability. Without consistency, “relative performance” becomes difficult to interpret.

One practical way institutions address this challenge is by complying with and requiring their managers to comply with the GIPS® standards.

The GIPS standards are a globally recognized framework administered by CFA Institute designed to promote fair representation and full disclosure in the calculation and presentation of investment performance.

Endowments and foundations that adopt the GIPS standards for their own performance calculations—and require the same of the managers they hire—send a powerful message to their boards and stakeholders that the institution is committed to transparency in how results are calculated and presented.  

3. Is reporting aligned with policy benchmarks?

Boards should see performance relative to long-term policy objectives, not just absolute returns. And this information should be shown at the level at which it is managed. Simply reporting that “the portfolio returned 8%” does not answer the real governance question.

A portfolio can have a positive year and still fail to meet its strategic role within the overall allocation.

For example:

  • Did the equity allocation meet its return objective relative to its benchmark?
  • Did the diversifying strategies provide the downside protection they were intended to deliver?
  • Did fixed income serve its role as a stabilizer?
  • Did alternative investments justify their complexity and liquidity constraints?

Even if the overall portfolio met its expected return, boards should understand how it got there. Reviewing performance by allocation allows boards to evaluate whether each segment is fulfilling its mandate, not just whether the total return looks acceptable.

When reported this way, it becomes easier to see where the portfolio is meeting expectations and where it may be falling short.

4. Is communication designed for governance?

Once performance is aligned to policy benchmarks, reporting should help trustees interpret what the results mean without requiring them to operate at the manager or security-selection level.

Reports should help answer key questions:

·        Are we meeting long-term objectives?

·        How are managers performing relative to their mandates?

·        Is risk aligned with the investment policy?

·        Are we preserving capital appropriately given our spending needs?

·        Did managers follow investment guidelines that align with our institution’s mission?

If any of these areas underperform, governance-level reporting should prompt clear, high-level discussion: Why did this occur? Was the result consistent with expectations? What steps, if any, are being considered to address issues going forward? If shortfalls persist, boards may need to evaluate whether the strategy or manager remains appropriate.

This kind of oversight strengthens outcomes by reinforcing accountability. Performance reporting should be communicated in plain language and simplify complex data into clear actionable insight. When this occurs, it enables boards to move from procedural review toward informed, effective governance.

From Calculation to Communication

Accurate returns are the starting point. Clear communicationis the outcome.

When performance calculation, oversight, and presentation are thoughtfully structured, board discussions become more strategic and less reactive. Boards gain confidence in their oversight, managers operate within clearer expectations, and the institution stays focused on its purpose.

A Closing Thought

Mission-driven institutions think in decades, not quarters. Their performance reporting should reflect that same discipline. Investment oversight is not just about generating returns, it is about ensuring those returns are measured, understood, and aligned with the institution’s long-term purpose.

Clear reporting strengthens governance.
Strong governance protects sustainability.
And sustainability protects the mission.

If you’ve been around the Global Investment Performance Standards (GIPS®) long enough, you know that governance is one of those topics everyone agrees is important, but far fewer firms can clearly explain what good governance with the GIPS standards actually looks like day to day.

Most firms don’t fail at GIPS compliance because they misunderstand a technical requirement. They struggle because ownership is unclear, decisions are informal, or key knowledge lives in one person’s head. When that person leaves (or when the firm grows) things start to break.

So, let’s simplify this.

Below is a practical, real-world view of what good governance looks like when complying with the GIPS standards—not in theory, not in a policy document that no one reads, but in how well-run firms actually operate.

Start with the Right Mindset: Governance Is About Sustainability

At its core, GIPS compliance exists to answer one question:

Can this firm consistently calculate, maintain, and present performance fairly and accurately—regardless of growth, staff changes, or market stress?

The GIPS standards are built on the principles of fair representation and full disclosure, but governance is what turns those principles into repeatable behavior. Good governance doesn’t mean more paperwork or compliance headaches. It means clear accountability, documented decisions, and controls that actually get used.

1. Clear Ownership (It’s Rarely Just One Person)

One of the most common governance risks we see is a “GIPS compliance department of one” where critical knowledge, decisions, and processes are concentrated with a single individual. While this can work in the short term, it creates challenges around continuity, oversight, and scalability as the firm grows or changes.

Good governance starts by clearly defining:

  • Who owns GIPS compliance overall
  • Who performs monthly/quarterly/annual tasks
  • Who reviews and approves key inputs/outputs
  • Who resolves judgment calls
  • Who ensures it also complies with other relevant regulations  

In practice, this often looks like:

  • A GIPS compliance committee or designated governance group
  • Representation from performance, compliance, operations, and senior management
  • Defined escalation paths for gray areas (e.g., discretion, composite changes, error corrections)

When a firm isn’t large enough to support a formal committee, outsourcing to a GIPS compliance consultant or a provider of managed services can be an effective alternative. These individuals can help you design policies, create procedures, and essentially manage governance for you.

But even if you are big enough, having an independent third party on your GIPS compliance committee can provide an objective, well-informed perspective formed by experience across many firms and a deep understanding of what works well in practice.

2. Policies and Procedures That Reflect Reality

Every GIPS compliant firm has GIPS standards policies and procedures (GIPS standards P&P). Well-governed firms actually use them.

Strong GIPS compliance governance means your GIPS standards P&P:

  • Include procedures your firm actually follows instead of only stating policies
  • Reflect how performance is really calculated
  • Clearly document firm-specific elections and judgments
  • Are updated when the business changes (for new products, systems, asset classes)

 

Think of your GIPS standards P&P as the firm’s operating manual for performance, not a static compliance artifact. If someone new joined your performance team tomorrow, they should be able to follow your policies and procedures to calculate performance and arrive at the same results. If not, governance needs work.

3. Formalized Review and Oversight

Good governance includes independent review, even if it’s internal.

In practice, this often means:

  • Secondary review of composite membership decisions
  • Review of significant cash flow thresholds and discretion determinations
  • Approval of new composites and composite definition changes
  • Oversight of error identification and correction

 

This is where governance protects firms from subtle but costly mistakes, especially those that show up during verification and increase complexity and scope of these engagements. In an ideal situation, these internal reviews should catch issues before they become problems.

As a provider of managed services, Longs Peak helps firms identify performance outliers, accounts that are breaking composite rules, and other data anomalies. This review significantly reduces the risk of erroneous data ending up in your performance and later caught in verification. If you are not able to do this internally, we strongly recommend outsourcing this effort.

4. Governance Extends to Marketing and Distribution

One area that has been increasingly important is the intersection of GIPS compliance, the SEC marketing rule, and how you manage the distribution of marketing materials.

Well-governed firms:

  • Control who can distribute GIPS Reports and how they are distributed
  • Ensure Marketing understands what is and is not an advertisement that meets the requirements of the GIPS standards
  • Coordinate GIPS compliance requirements with broader regulatory rules, including the SEC marketing rule
  • Have a clear process for tracking distribution

 

This alignment helps firms avoid inconsistencies between factsheets, pitchbooks, and GIPS Reports—one of the fastest ways to lose credibility with prospects and regulators.

Some clients prefer not to mention GIPS compliance at all in their marketing (i.e., on their factsheets and pitchbooks) until a client is clearly interested in one of their strategies. Once they meet the definition of a prospect (as outlined in your GIPS standards P&P), it triggers the requirement to send a GIPS Report and they find this smaller list of prospects easier to maintain. For others, having everything in one document including required GIPS compliance information and disclosures is easier to manage than separate documents.

There is no “right” way to manage this, but in either case, having a clear process for tracking and reporting performance errors is key.

5. Documentation of Decisions (Not Just Results)

Here’s a subtle but critical point: Good governance for your GIPS compliance program documents decisions, not just outcomes.

Why was that composite redefined?
Why was this benchmark changed?

Why was this model fee selected?

Strong governance creates an audit trail that:

  • Supports sound reasoning (which aides in the verification process or even regulatory exams later on)
  • Reduces key person risk
  • Makes future reviews faster and less stressful

 

This is especially valuable when firms grow, merge, or experience turnover. Clear documentation allows others to step in seamlessly and continue critical functions without disruption. More importantly, it enables independent parties, such as a regulator or your verifier, to understand, assess, and validate how you are calculating and presenting performance that may not be immediately intuitive.

6. Governance Is Ongoing, Not a One-Time Project

The best-governed firms don’t “set and forget” their GIPS compliance program. They revisit governance when:

  • New strategies launch
  • Systems or custodians change
  • Regulations evolve
  • The firm’s structure changes

In other words, governance evolves with the business—because performance reporting doesn’t exist in a vacuum.

Even for firms that are not regularly launching new strategies, changing systems or structure, an annual review of your GIPS compliance program and governance framework is critical. This review helps confirm that practices have remained consistent, while also providing an opportunity to reflect on whether you are satisfied with your verifier, assess whether new regulations require updates, and reconsider how composites are managed or described.

The best time to do this is at year-end so that if you decide something should be changed, you can do that proactively for the upcoming year, rather than having to fix it retroactively.

What Good GIPS Compliance Governance Really Buys You

When GIPS compliance governance is working well, firms experience:

  • A structured, intentional process for validation of your performance results
  • A framework that supports consistency and transparency over time
  • Fewer surprises or last-minute scrambles during verification or regulatory review
  • Greater confidence from regulators and verifiers that you are following established policies and procedures
  • Lower operational and reputational risk

 

Most importantly, it creates trust internally and externally. Good GIPS compliance governance isn’t about being perfect. It’s about being intentional.

Clear ownership. Thoughtful documentation. Real oversight. Those are the firms that don’t just claim compliance, they live it.

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