Are ETFs A Better Benchmark?
Jocelyn Gilligan, CFA, CIPM
Partner
June 28, 2024
15 min
Using Exchange-Traded Funds (ETFs) as benchmarks instead of traditional indices has become a common practice among investors and fund managers. ETFs offer practical advantages, such as reflecting real-world trading costs, and incorporating management fees and tax considerations. These aspects make ETFs a more accurate and accessible benchmark as they are an actual investible alternative to the strategy being assessed.
However, this approach is not without its drawbacks. Understanding both the advantages and disadvantages of using ETFs as benchmarks is crucial for making informed investment decisions and ensuring accurate performance comparisons.
This article discusses the pros and cons of using an ETF as a benchmark and considerations for making an informed decision on how to go about selecting one that is meaningful.
The Advantages:
Using an ETF as a benchmark rather than the underlying index has several advantages. These include:
Cost:
The decision to use an ETF rather than an actual index as a benchmark often stems from the costs associated with using index performance data. While index providers typically charge licensing fees for access to their indices, these fees can be cost-prohibitive for some firms, especially smaller ones, or those with limited resources.
ETFs offer a more accessible and cost-effective alternative, as they provide readily available, real-time performance data and can be traded easily on stock exchanges and accessed by anyone. By using an ETF as a benchmark, firms can circumvent the barriers to entry associated with marketing index performance directly, allowing them to still compare performance against a relevant benchmark.
Practical Investment Comparison:
ETFs represent actual investment vehicles that investors can buy and sell, thus providing a more practical and realistic performance comparison. Indices, on the other hand, are theoretical constructs that do not account for real-world trading costs, whereas ETFs do. Additionally, ETFs are traded on stock exchanges and can be bought and sold throughout the trading day at market prices, unlike indices which cannot be directly traded.
Incorporation of Costs:
ETFs include trading and management expenses and other costs associated with managing the pool of securities. When using an ETF as a benchmark, you get a more accurate reflection of the net returns an investor would actually receive after these costs. In addition, ETF performance considers the costs of buying and selling the underlying assets, including bid-ask spreads and any market impact, which indices do not.
Dividend Reinvestment:
ETFs may account for the reinvestment of dividends, providing a more accurate measure of total return. Indices often do not factor in the practical aspects of dividend reinvestment, such as timing delays, transaction costs, and tax implications, leading to a potentially less realistic depiction of investment returns.
Tax Considerations:
ETFs may have different tax treatments and efficiencies compared to the theoretical index performance. Using an ETF as a benchmark will reflect these considerations, providing a potentially more relevant comparison for taxable investors.
Replication and Tracking Error:
ETFs can exhibit tracking error, which is the deviation of the ETF's performance from the index it seeks to replicate. While tracking error may be perceived as a limitation, it also reflects the real-world challenges and frictions involved in managing an investment portfolio. Thus, using an ETF as a benchmark encompasses this aspect of real-world performance—which acknowledges the practical complexities of investing and serves to enhance transparency and accountability in investment decision making.
Transparency and Real-time Data:
ETFs provide real-time pricing information throughout trading hours, allowing investors to monitor and compare performance continuously as market conditions fluctuate. This real-time data enables more informed and timely decision-making, as investors can react instantly to market events, manage risks more effectively, and capitalize on opportunities as they arise.
Advantages Summary
In summary, using an ETF as a benchmark provides a less-costly, more realistic, practical, and accurate measure of investment performance that includes real-world considerations like costs, liquidity, tax implications, and dividend reinvestment, which are not fully captured by indices. ETFs are a true investable alternative, while indexes are not directly investible.
The Disadvantages:
While using an ETF as a benchmark has several advantages, there are also some potential drawbacks to consider:
Downside of Tracking Error:
ETFs may not perfectly track their underlying indices due to various factors such as imperfect replication methods, sampling techniques, and management decisions. This tracking error can result from differences in timing, costs, and portfolio composition between the ETF and its benchmark index.
This deviation can lead to discrepancies when comparing the ETF's performance to the actual index and can affect investors' expectations, portfolio management decisions, and performance evaluations. Thus, it is prudent to evaluate and monitor tracking error of ETFs when they are used as a benchmark.
Tracking Method: Full Replication vs. Sampling
ETFs employ different replication strategies to track their underlying indices, with some opting for full replication, while others utilize sampling techniques. These differences can lead to varying levels of tracking error and performance differences from the underlying index.
Full replication involves holding all of the securities in the index in the same proportions as they are weighted in the index, aiming to closely mirror its performance. In contrast, sampling techniques involve holding a representative subset of securities that capture the overall characteristics of the index.
While full replication theoretically offers the closest tracking to the index, it can be more costly and logistically challenging, especially for indices with a large number of securities. Sampling, while potentially more cost-effective and manageable, introduces the risk of tracking error, as the subset of securities may not perfectly reflect the index's performance.
Non-Comparable Expense Ratios:
ETFs incur management fees, which reduce returns over time. While these fees are part of the real-world costs, they can make the ETF's performance look worse compared to the theoretical performance of the index, especially when compounded over time. This may be problematic when using an ETF as a comparison tool (think expense ratios dragging down ETF benchmark performance thus making the strategy appear to have performed better than it would have against the actual index). This has the potential to influence investment decisions and performance evaluations. To address this concern, the GIPS Standards now require firms that use an ETF as a benchmark to disclose the ETF’s expense ratio.
Many active managers might argue that it’s “unfair” that the SEC requires them to compare net returns against an index that has no fees or expenses. However, if the strategy’s goal is to beat the index with active management, the manager should be doing this even after fees, otherwise passive investing (with lower fees) is a better option.
Liquidity Constraints:
Some ETFs may suffer from lower liquidity, leading to wider bid-ask spreads and higher trading costs, especially for large transactions. This can affect the ETF's performance and make it less ideal as a benchmark.
Selection Dilemma
Multiple ETFs may track the same index, each with different structures, expense ratios, and tracking accuracy (e.g., check out the differences between SPY, IVV, VOO, SPLG). As a result, choosing the most appropriate ETF as a benchmark should involve consideration of factors such as cost-effectiveness, liquidity, tracking error, and the strategy’s specific investment objectives. As a result, some due diligence should be done to ensure that the selected ETF aligns closely with the desired index and makes sense for the investment strategy.
Some firms have made it a habit to mix the use of different ETFs in factsheets, often because their data sources lack all the data needed for one ETF. While it may seem like it’s all the same, for many of the reasons discussed in this post, not all ETFs are created equal. We do not recommend mixing benchmarks, even when using actual indices (e.g., comparing performance returns to the Russell 1000 Growth, but then showing other statistics like sectors compared to the S&P 500). Similarly, we wouldn’t recommend doing that with ETFs either (e.g., comparing performance returns to IVV but using sector information from SPY). Mixing benchmark information in factsheets is messy and likely to be questioned by regulators, especially when doing so makes strategy performance look better.
Regulatory and Structural Issues:
ETFs are subject to evolving regulatory oversight that might affect their operations, costs and performance as benchmarks. This is not the case for indices.
In addition, the structural differences between ETFs, particularly regarding whether they are physically backed or use synthetic replication through derivatives, can significantly impact their risk profile and performance relative to their underlying indices.
Physically backed ETFs typically hold the actual securities that comprise the index they track, aiming to replicate its performance as closely as possible. In contrast, synthetic ETFs use derivatives, such as swaps, to replicate the index's returns without owning the underlying assets directly. While synthetic replication can offer cost and operational advantages, it also introduces counterparty risk, as the ETF relies on the financial stability of the swap provider.
As a result, it’s best to consider the structure of the ETF before using it as a benchmark.
Market Influences:
ETFs can trade at prices above (premium) or below (discount) their net asset value (NAV), which can introduce short-term performance differences that are not reflective of the underlying index performance.
These premiums and discounts arise due to supply and demand dynamics in the market, as well as factors such as investor sentiment, liquidity, and trading volume. These fluctuations can affect the ETF's reported returns and introduce discrepancies when comparing its performance to the benchmark index. Therefore, investors must consider the impact of these premiums and discounts on the ETF's short-term performance and recognize that these variances may not accurately represent the true performance of the underlying index.
When material differences in price vs. NAV exist, some firms believe that the NAV is a better representation of the fair value rather than the price and have used NAV for performance calculations. Please note that when this is done, it is important to document how fair value is determined and if the performance is based on the change in NAV or change in trading price.
Currency Risk:
Investors utilizing ETFs tracking international indices face the added complexity of currency fluctuations, which can significantly influence the ETF's performance. When investing in foreign ETFs, investors are exposed to currency risk, as fluctuations in exchange rates between the ETF's base currency and the currencies of the underlying index's constituents can impact returns. Currency movements can either enhance or detract from the ETF's performance, depending on whether the base currency strengthens or weakens relative to the underlying currencies.
Consequently, currency risk should be considered when using international ETFs as benchmarks.
Dividend Handling:
The handling of dividends by ETFs, whether they are paid out to investors or reinvested back into the fund, can have a notable impact on their total return compared to the index they track. Indices typically assume continuous reinvestment of dividends without considering real-world frictions such as transaction costs or timing delays associated with reinvestment. In contrast, ETFs may adopt different dividend distribution policies based on investor preferences and fund objectives.
ETFs that reinvest dividends back into the fund can potentially enhance their total return over time by capitalizing on the power of compounding. However, this approach may result in tracking errors if the reinvestment process incurs costs or timing discrepancies that deviate from the index's assumed reinvestment.
ETFs that distribute dividends to investors as cash payments may offer more immediate income but could lag behind the index's total return if investors do not reinvest these dividends efficiently. Therefore, the dividend handling policy adopted by an ETF can significantly influence its performance relative to the index and should be carefully considered.
Lack of Historical Data:
Some ETFs, especially newer ones, may not have a long track record. This can make historical performance comparisons less reliable or comprehensive. Without an extensive performance history, sufficient data may be lacking to assess an ETF's performance across various market conditions and economic cycles, making it challenging to gauge its potential risks and returns accurately.
Strategies that existed long before an ETF was created to track the comparable index, may end up with timing differences. Many firms often need to use multiple benchmarks to cover the entire period. But, for some strategies that go way back, an ETF may not exist back to inception. Be sure to include rationale in your documentation for benchmark selection so that it is clear when and why a benchmark was selected for the given time periods.
Conclusion:
In conclusion, using ETFs as benchmarks offers practical benefits, potentially making them a more accurate and accessible measure of investment performance compared to traditional indices since they are an actual investable alternative to hiring an active manager. However, these benefits do not come without shortcomings. By carefully evaluating these factors and considering the specifics of the ETFs selected for each strategy, managers can effectively use ETFs as benchmarks to assess and monitor investment strategies. In understanding these factors, an ETF may actually be a better comparison tool for your strategy than the underlying index.
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Part 2: Creating GIPS Policies and Procedures
June 22, 2017
15 min
Calculation Methodology, Books & Records, Composite Definitions & Rules, and Error Correction Policies
As discussed in Part 1 of this two part series, GIPS compliant firms are required to document how they comply with the GIPS requirements as well as any recommendations that the firm chooses to follow. This document acts as the firm’s internal representation of their GIPS compliance, and is intended to state the firm’s policies and describe the procedures the firm follows to maintain its compliance.
In Part 1 of this two part series we covered Firm Definition and Definition of Discretion. Now, in Part 2 we will cover calculation methodology, books and records, composite definitions and rules, as well as error correction policies.
https://www.youtube.com/watch?v=UhaTy-4c-EM&feature=emb_logo
Calculation Methodology
While GIPS provides a framework for how to calculate performance, firms may have different methods for handling external cash flows, asset-weighting portfolios, calculating dispersion, etc. The specifics of the methods used must be documented in the firm’s GIPS P&P. This section is typically broken down to separately discuss portfolio-level calculation methodology and composite-level calculation methodology.
The main consideration when establishing your firm’s portfolio-level methodology is the treatment of external cash flows. Since the start of 2010, GIPS requires firms to revalue for all “large” cash flows. It is up to your firm to define the term “large,” but it should be defined based on when your firm feels that estimation methods, such as Modified Dietz, lose their accuracy. Most portfolio accounting systems either value portfolios daily (essentially defining “large” as 0%) or value portfolios for all cash flows 10% or greater. Firms without a portfolio accounting system that are calculating their portfolio-level performance more manually (e.g., in Excel) frequently use 20%, but higher than that is less common.
With regard to composite-level performance, the most important information to document is the method used to asset-weight the portfolio returns to get the composite-level performance results. This is typically achieved through one of the following three methods:
- Asset-weight each individual portfolio’s return for the month based on each portfolio’s beginning market value and then sum the portfolios’ weighted returns to get the composite return for the month.
- Asset-weight each individual portfolio’s return for the month based on each portfolio’s beginning market value plus weighted cash flows and then sum the portfolios’ weighted returns to get the composite return for the month.
- Aggregate the underlying data of all portfolios in the composite and then calculate the performance for each month as if all of the aggregated data is for one large portfolio.
This section should also include information regarding how the other required GIPS statistics are calculated, such as dispersion and 3-year annualized ex post standard deviation. Here, it is important to note whether these statistics are calculated based on gross or net-of-fee returns, whether calculated by your portfolio accounting system or outside the system, (e.g., in Excel) and the specific standard deviation formula used to do the calculation (e.g., a population or sample based formula).
Policies Regarding Books and Records
Firms must be able to support all information included in GIPS compliant presentations as well as support that their client assets are real. This section of your GIPS P&P can outline the types of records that are maintained and in what format/location they are stored. Specifically, firms typically outline the types of documents they have (e.g., custodial statements, records maintained within a portfolio accounting system, printed records from a former portfolio accounting system such as holdings reports, transaction summaries, etc.). In this section, it is also important to mention whether files are hardcopy or electronic, whether they are maintained onsite or offsite, and if there is a limit to the amount of time they are saved.
Composite Definitions and Rules
irms must create policies to ensure that portfolios are placed in the appropriate composite for the correct time period. The timing of portfolio movement in or out of composites must be based on objective criteria that is outlined in this section of the firm’s GIPS P&P. For example, firms typically either set a policy based on the amount of time passed since discretion was granted or based on when the portfolio becomes “fully invested” – which must be clearly defined.
For example, if based on time, the policy may be written as, “portfolios are included in the composite at the start of the first full month under management.” If based on when the portfolio becomes fully invested, the policy may be written to state, “portfolios are included in the composite at the start of the first full month after the portfolio is at least 90% invested in line with the strategy.” The percentage set can be whatever your firm feels is appropriate, but you want to establish a clear threshold that can be followed. Simply stating “fully invested” is subjective and difficult to follow consistently.
Other rules can also be documented in this section such as minimum asset levels and significant cash flow thresholds, to keep portfolios out of composites during periods where the intended strategy cannot be fully implemented. Minimum asset levels set for GIPS composite purposes are different than minimums your firm may set for marketing purposes. While your firm can state any marketing minimum you wish based on the size portfolios you hope to attract, the minimum set for composite inclusion must be based on the minimum amount needed to fully implement that strategy. For example, even if your firm states that your strategy has a $1M minimum, portfolios accepted below this threshold must still be included in the composite if they can be managed the same as the portfolios over $1M. In this example, if you determine that below $500k you can no longer diversify the same way as you do for your larger portfolios, then $500k would be an appropriate minimum to set for composite inclusion purposes.
A significant cash flow policy can be established if your firm is concerned with very large cash flows moving in or out of a portfolio. Often these cash flows affect the portfolio’s performance and could distort the composite’s statistics. Firms wishing to implement a significant cash flow policy establish a threshold for the size of a cash flow (typically based on the percentage of the portfolio’s beginning of month market value) that would trigger the temporary removal of the portfolio from the composite while trading takes place to accommodate the cash flow.
This “significant” cash flow threshold is different than the “large” cash flow threshold discussed in the calculation methodology section. While the “large” cash flow threshold is set to improve the mathematical accuracy of the performance calculation, the “significant” cash flow threshold is based on the size of a cash flow that disrupts the actual management of the portfolio. Significant cash flows often lead to distorted performance figures that were out of the portfolio manager’s control in terms of timing or amount.
Error Correction Policies
Firms must create materiality thresholds that pre-determine the action required if errors occur in a compliant presentation. This section should include thresholds for all statistics as well as criteria for determining when errors in disclosures are material. Defining materiality thresholds can be difficult, but CFA Institute, in conjunction with the United States Investment Performance Committee (USIPC), conducted a GIPS error correction survey seeking information regarding the typical materiality thresholds used by GIPS compliant firms. We recommend reviewing the Executive Summary of this survey’s results to get an idea of the thresholds that have been set by your peers.
Typically, thresholds are set that define the level when an error becomes a material error. Anything above the threshold would require the firm to redistribute an amended GIPS compliant presentation to any prospective client or clients that relied on the erroneous presentation. This amended GIPS compliant presentation would also need to include a disclosure that explains the correction. Anything below the materiality threshold will only trigger a correction for future distributions, but no disclosure or redistribution of previously circulated presentations.
Updates for GIPS 2020
The GIPS standards were updated in 2020. Check out our post How to Update Your GIPS P&P for GIPS 2020 to make sure your P&Ps are consistent with these changes.
Want to Learn More?
If you have any questions about the GIPS Standards, we would love to help. Longs Peak’s professionals have extensive experience helping firms become GIPS compliant as well as helping them maintain compliance with the GIPS Standards on an ongoing basis.
GIPS Compliance Actions for the New Year 2020
January 9, 2022
15 min
Your firm works hard to comply with the Global Investment Performance Standards (GIPS®) and likely expects the benefits of GIPS to far outweigh any burden associated with maintaining compliance. Most of the policies and procedures your firm set when first becoming compliant will never need to change; however, as both the standards and your firm evolves, it is beneficial to conduct a high-level review of your GIPS compliance each year. This high-level review will help ensure that you continually refine your processes and policies to maximize the benefits of claiming compliance with GIPS year after year.
This year, conducting a review of your firm’s GIPS compliance is especially important because of the 2020 Edition of the GIPS Standards that was published in mid-2019. For information specific to the 2020 changes, please check out 2020 GIPS Standards: Prepare for the Changes.
Even without the release of a new edition of the standards, each year you should conduct a review. In the review, you should first make sure you have the right people involved. One person or department may be responsible for managing the day-to-day tasks that maintain your GIPS compliance; however, high-level oversight from a larger group should take place to help ensure that any decisions made or policies set will integrate well with your firm’s other strategic initiatives. This larger group, often called a GIPS Committee, typically consists of representatives from compliance, marketing, portfolio management, operations/performance, and senior management.
Not everyone on the committee needs to be an expert in the GIPS standards. In fact, many will not be. What they will need is to be available to share their opinions and represent their department’s interests when establishing or changing key policies for your firm. Your GIPS compliance expert/manager can set the agenda for your meeting and can provide any background on the requirements that will be part of the discussion. If you do not have a GIPS expert internally, or need independent advice about your policies and procedures, a GIPS consultant can be hired to help.
High-Level GIPS Topics to Consider Annually
Once you select the right group to represent each major area of your firm, the following high-level questions can help determine if any action is necessary to improve your GIPS compliance this year:
- Have there been any changes to the GIPS standards?
- Have there been any material changes to your firm or strategies?
- Do your composites meaningfully represent your strategies or should their structure and descriptions be reconsidered?
- Are the materiality thresholds stated in your error correction policy appropriate for the type of strategies you manage and are they consistent with the thresholds set by similar firms?
- Are you satisfied with the service received from your GIPS verifier for the fee that is paid?
- Is there any due diligence you need to conduct on your verification firm?
Changes to the GIPS Standards
It is important to consider whether there have been any changes to the GIPS standards since last year that would require your firm to take action. For example, if a new requirement is adopted, you should consider if any changes to your firm’s policies and procedures or GIPS Reports are needed.
Keep in mind that GIPS compliant firms must comply with all requirements of the GIPS standards including any updates that may be published in the form of Guidance Statements, Questions & Answers (Q&As), or other written interpretations.
If your firm is verified or works with a GIPS consultant, these GIPS experts are likely keeping you informed of any changes to the standards. The best way to check for changes yourself is to visit the “Standards & Guidance” section of www.gipsstandards.org. Specifically, you should check the “GIPS Q&A Database” where you can enter the effective date range of the previous year to see every Q&A published during this period. You should also check the “Guidance Statements” section. The guidance statements are organized by year published, so it is easy to see when new statements are added.
With the new 2020 Edition of the GIPS Standards, a review of the changes to determine how they affect your firm is especially important this year. These changes must be fully adopted before presenting returns in your GIPS reports for periods ending on 31 December 2020 or later.
Changes to Your Firm or Strategies
Similar to changes in the standards, it is important to also consider whether any changes to your firm or its strategies would require you to take action. Examples include, material changes in the way a strategy is managed, a new strategy that was launched, an existing strategy that closed, mergers or acquisitions, or anything else that would be considered a material event for your firm.
Even if no changes were made this year, you should still read your entire policies and procedures document at least annually to make sure it adequately and accurately describes the actual practices followed by your firm. Regulators, such as the Securities and Exchange Commission (SEC), commonly review firms’ policies and procedures to ensure 1) that the document includes actual procedures and is not simply a list of policies and 2) that the stated procedures truly represent the procedures followed by the firm. Many firms have created their policies and procedures document based on template language, so tweaks may be necessary to customize the document for your firm.
Meaningful Composite Structure
The section of your GIPS policies and procedures requiring the most frequent adjustment is your firm’s list of composite descriptions, as you must make changes each time a new composite is added or if a composite closes. However, even without adding new strategies or closing older strategies, the list of composite descriptions should be reviewed at least annually to ensure they are defined in a manner that best represents the strategies as you manage them today.
Since your firm’s prospects will compare your composite results to those of similar firms, it is important that your composites provide a meaningful representation of your strategies and are easily comparable to similar composites managed by your competitors. If a review of your current list of composite descriptions leads you to realize that your strategies are defined too broadly, too narrowly, or in a way that no longer accurately describes the strategy, changes can be made (with disclosure).
Keep in mind that changes should not be made frequently and cannot be made for the purpose of making your performance appear better. Changing your composite structure for the purpose of improving your performance results, as opposed to improving the composite’s representation of your strategy, would be considered “cherry picking.”
Two examples of cases that may require a change in your composites include:
- A strategy has evolved and certain aspects of the way the strategy was managed and defined in the past are different from today. This can be addressed by redefining the composite. Redefining the composite requires you to disclose the date and description of the change. This disclosure will help prospects understand how the strategy was managed for each time period presented and when the shift in strategy took place. Changes like this should be made to your composite descriptions at the time of the change, but an annual review can help you address any items that may have been overlooked when the change occurred.
- A composite is defined broadly to include all large capitalization accounts. Within this large capitalization composite, there are accounts with a growth focus and others with a value focus. If your closest competitors are separately presenting large capitalization growth and large capitalization value composites, your broadly defined large capitalization composite may be difficult for prospects to meaningfully compare to your competitors. To address this, you can create new, more narrowly defined composites to separate the accounts with the growth and value mandates. In this case, the full history will be separated and the composite creation date disclosed for these new composites will be the date you make the change. Note that this will demonstrate to prospective clients that you had the benefit of hindsight when determining the definition.
Materiality Thresholds Stated in Your Error Correction Policy
Another section of your firm’s GIPS policies and procedures that should be reviewed in detail is your error correction policy. Your error correction policy includes thresholds that pre-determine which errors (of those that may occur in your GIPS Reports) are considered material versus those deemed immaterial. These thresholds cannot be changed upon finding an error; however, they can be updated prospectively if you feel a change would improve your policy.
Many firms had a difficult time setting these thresholds when this requirement first went into effect back at the start of 2011. Now that much more information is available to help you determine these thresholds, such as the GIPS Error Correction Survey, you may want to revisit your policy to ensure it is adequate.
Setting and approving materiality thresholds that determine material versus immaterial errors is a task best suited for your firm’s GIPS committee rather than your GIPS department or manager. The reason for this is that opinions of what constitutes a material error will vary from one department to another. Your committee can help find a balance between those with a more conservative approach and those with a more aggressive approach to ensure the thresholds selected are appropriate.
GIPS Verifier Selection and Due Diligence
If your firm is verified, it is important to periodically evaluate whether you are satisfied with the quality of the service received for the fees paid. You may also want to consider whether you need to conduct any periodic due diligence on your verification firm with respect to data security or other concerns important to your firm.
With several mergers, acquisitions, and start-ups in the verification community over the last few years, you may need to do some research to ensure you are familiar with what your options are when selecting a verification firm.
All verifiers have the same general objective: to test and opine on 1) whether your firm has complied with all of the composite construction requirements of the GIPS standards and 2) whether your firm’s GIPS processes and procedures are designed to calculate and present performance in compliance with GIPS. Where they differ is in the fees charged and process followed to complete the verification.
With regard to fees, much of the difference between verifiers is based on their level of brand recognition rather than differences in the quality of their service. For example, smaller firms specialized in GIPS verification may have more experience with the intricacies of GIPS compliance than a global accounting firm; yet, a global accounting firm will likely charge a higher fee. When selecting a higher fee firm, it is important to consider whether the higher fee is offset by the benefit your firm receives when listing their brand name as your verifier in RFPs you complete.
With regard to process, the primary difference between verification firms is whether the verification testing is done onsite or remotely. There are pros and cons to both methods and it is important for your firm to consider which works best for the team that is fielding the verification document requests. The onsite approach may result in finishing the verification in a shorter period, but may be disruptive to your other responsibilities while the verification team is in your office. The remote approach may be less disruptive to your other responsibilities, but likely will take longer to complete and may be less efficient as documents are exchanged back and forth over an extended period of time. Another difference is how the engagement team is structured, whether you can expect to work with the same team each year, and how much experience your main contact has.
Regardless of whether the verification is conducted onsite or remotely, be sure to ask any verifier how your proprietary information and confidential client data is protected. If the work is done remotely, how are sensitive documents transferred between your firm and the verifier (e.g., is it through email or a secure portal) and once received by the verifier, do they have strong controls in place to ensure your data is not breached.
If the work is done onsite, it is important to ask what documents (or copies of documents), if any, the verifier will be taking with them when they leave, and whether these documents are saved in a secure manner. Documents saved locally on a laptop are at higher risk of being compromised.
Questions?
For more information on how to maximize the benefits your firm receives from being GIPS compliant or for other investment performance and GIPS compliance information, contact Sean Gilligan at sean@longspeakadvisory.com.
How to Become GIPS Compliant
May 24, 2017
15 min
Many firms are interested in becoming GIPS compliant, but are intimidated by the initial process of bringing their firm into compliance. As long as you know the steps to become GIPS compliant and understand the options you have to complete each step, this process is very manageable. The information provided here is intended to provide you with a high-level overview of the steps you must complete to become GIPS compliant.
https://www.youtube.com/watch?v=E6zBnbW_OMU&feature=emb_logo
Before holding your firm out to the public as a GIPS compliant firm, there are three main steps that must first be completed. Firms must:
- Document GIPS policies and procedures
- Construct composites that consistently follow these policies and procedures
- Create compliant presentations to show the results of each composite
Document GIPS Policies and Procedures
Firms are required to document how they comply with the GIPS requirements as well as any recommendations that the firm chooses to follow in a document known as the firm’s GIPS Policies and Procedures (“GIPS P&P”). This document acts as the firm’s internal representation of their GIPS compliance, and is intended to state the firm’s GIPS policies as well as describe the procedures the firm follows to maintain their compliance. Examples of items typically found in this document include:
- Firm Definition – GIPS is applied to your firm as a whole, not to a single product or strategy you manage. How your firm is defined for GIPS purposes is primarily based on how the firm is held out to the public, which may differ from the legal structure of your firm.
- Definition of Discretion –Discretion is defined differently for GIPS than it typically is for legal or regulatory purposes. You may have a discretionary contract for an account that you deem to be non-discretionary for GIPS purposes because of restrictions the client places on the implementation of the strategy. The “Definition of Discretion” section of your firm’s GIPS P&P should outline objective criteria for determining the discretionary status of accounts.
- Policies Regarding Books and Records – Firms must be able to support all information included in compliant presentations as well as support that their client assets are real. This section of your P&P can outline the types of records that are maintained and in what format/location they are stored.
- Calculation Methodology – While GIPS provides a framework for how to calculate performance, firms may have different methods for handling external cash flows, asset-weighting accounts, calculating dispersion, etc. The specifics of the methods used must be documented in the firm’s GIPS P&P.
- Composite Definitions and Rules – Firms must create policies to ensure that accounts are placed in the appropriate composite for the correct time period. The timing of the movement of accounts in or out of composites must be based on objective criteria that is outlined in this section of the firm’s GIPS P&P. Other optional rules, such as minimum account sizes and significant cash flow thresholds can also be documented here to keep accounts out of composites during periods where the intended strategy cannot be fully implemented.
- Error Correction Policies – Firms must create materiality thresholds that pre-determine the action required if errors occur in a compliant presentation. This section should include thresholds for all statistics as well as criteria for determining when errors in disclosures are material.
Construct Composites
After the GIPS P&P is created, firms can use these policies to construct the composites defined in the policy document. To do this, firms must:
- Identify all of the accounts that meet the definition of a composite. In other words, group all accounts by strategy, but then remove accounts that do not meet the firm’s definition of discretion or that do not meet a composite-specific rule, such as a minimum account size.
- Determine the correct time to include each account as well as remove any account that closed, changed strategies, or otherwise caused you to lose discretion. Portfolios must only be included in composites for periods in which they were considered discretionary for GIPS purposes. This helps ensure that the composite results accurately represent the firm’s management of the composite’s strategy and does not include outside noise created from client-requested restrictions.
- Asset-weight the monthly account-level results for each account included in the composite to calculate the composite-level performance results.
- Calculate all required composite-level statistics (see the list below) that must be included in the composite’s compliant presentation.
Create Compliant Presentations
Compliant presentations act as the firm’s external representation of their GIPS compliance and must be provided to all prospective clients. Each composite has a separate presentation that includes all of the required statistics as well as the required disclosures. Statistics included in compliant presentations include:
- Annual composite performance (gross and/or net)
- Annual benchmark performance
- Number of accounts in the composite as of each year-end
- Total assets in the composite as of each year-end
- Total assets of the GIPS firm as of each year-end
- A measure of internal dispersion for each annual period
- Three year annualized ex-post standard deviation of both the composite and the benchmark based on monthly returns
Other statistics may also be required such as the percentage of non-fee paying accounts or the percentage of bundled fee paying accounts as of each year-end, where applicable.
Want to Learn More?
If you have any questions about how to become GIPS Compliant, we would love to help. Longs Peak’s professionals have extensive experience helping firms become GIPS compliant as well as helping them maintain compliance with the GIPS Standards on an ongoing basis.
How to Comply with the 2020 GIPS Standards
April 23, 2020
15 min
A new decade is upon us and with the new decade comes a series of new requirements in terms of investment performance reporting for firms and asset owners that elect to claim compliance with the GIPS standards.
Many organizations have elected to adopt the 2020 edition of the GIPS standards early and have already put a solid foundation in place for the updated requirements; however, many organizations have not. The adoption deadline for all compliant organizations is rapidly approaching, so if your organization has not begun this conversion, now is the time to get started.
What is Changing and Why
It has been over a decade since the last edition of the GIPS standards was released, and quite frankly, the industry has changed since 2010. As the industry has evolved, CFA Institute has released a number of Q&A’s, guidance statements, and interpretations on how the changes in the industry impact the standards.
Ten years of updates have resulted in a vast repository of information needed to obtain the guidance required to comply. Having so many different resources for guidance (the 2010 GIPS Handbook, separate guidance statements, the Q&A database, and the GIPS Help Desk) has made managing the requirements of GIPS a pretty daunting task; thus, one of the goals of the 2020 standards is to centralize all of the updates that have come out over the past ten years. The 2020 GIPS standards consolidates many of the concepts previously addressed in guidance statements and Q&A’s, allowing the new provisions and explanation of the provisions to serve as the primary source that firms, asset owners, verifiers, and consultants can look to for guidance.
Additionally, the 2010 standards were heavily focused on composites and the traditional definition of prospective clients. Using this as the main framework is not always applicable to organizations that primarily manage pooled funds or asset owners that do not compete for business or report performance to prospective clients. To address this, CFA Institute set out to make this new edition of the standards more applicable to pooled fund managers and asset owners. These updates were designed to make claiming compliance easier and more relevant for these types of managers, while not creating additional burdens on organizations that are already compliant with GIPS. This goal is evident in the new format of the provisions, which separately focuses on requirements for investment firms, asset owners, and verifiers.
In addition to the separation of pooled funds and composites, the guidance is broader on when organizations may present money-weighted returns instead of time-weighted returns. This change now allows the decision to be based on the investment vehicle structure and who controls the timing and amount of external cash flows, rather than limiting money-weighted returns to certain asset classes. This is a welcomed update in the industry as many organizations were frustrated by requirements to calculate and present time-weighted returns when this type of return was not the most meaningful representation of how they managed their investment strategies.
How the 2020 GIPS Standards are Organized
For ease of use and navigation, the 2020 GIPS standards is broken out into three different groups of tailored provisions – firms, asset owners, and verifiers. Each containing specific requirements and recommendations applicable for that type of organization.
As an organization claiming compliance or working to become compliant for the first time, you will need to determine whether the set of requirements for firms or assets owners is applicable to your claim of compliance. The primary distinguishing factor is whether your organization competes for business and manages external money, or reports to an oversight board and manages internal money. The answer to this determines which set of tailored provisions should be followed and sets the framework for how the standards will apply.
Where to Start – GIPS Compliance Updates
Regardless of whether you are excited for the updates to the standards, they are coming and will be required for all firms and asset owners claiming compliance with GIPS. The new requirements take effect once your GIPS Reports (formerly called Compliant Presentations) present performance information that is inclusive of the period 31 December 2020.
There is a lot of information available and dissecting everything that has been released can be overwhelming. For organizations that have never claimed compliance, the good news is that the new standards are more applicable and easier to adopt than they were previously.
For most organizations currently claiming compliance, what’s great is that the new standards do not require a lot of changes, rather they mostly provide optional procedures that you may choose to adopt if you find it beneficial to do so. However, some firms will require more work.
At Longs Peak, we have created the following questionnaire designed to help you determine if converting to the 2020 GIPS standards will require more than a few minor tweaks. This list does not include all changes, but includes the top ten material changes that may require a project plan to implement the required changes by the effective date of the 2020 GIPS standards.
Answering “Yes” to any of the following questions means your organization may require more than a few quick tweaks to implement the 2020 changes:
GIPS 2020 Checklist
- Does your firm have limited distribution pooled funds (i.e., private funds that are not regulated under a framework that would permit the general public to purchase shares in the fund without a one-on-one presentation)?
- Has your firm created single account composites for pooled funds solely for the purpose of meeting the GIPS requirement of having every discretionary, fee-paying portfolio in at least one composite?
- Does your firm have multi-strategy portfolios (e.g., balanced portfolios where the equity and fixed income segments each could be represented as standalone strategies) where you would like to carve-out the individual strategies into their own composites?
- Does your firm have portfolios where actual transaction costs are unavailable (e.g., wrap accounts or other bundled fee arrangements) and you would like to estimate transaction costs to show gross-of-fee returns without labeling the returns as supplemental information?
- Does your firm have portfolios where your firm controls the amount and timing of external cash flows (other than for private equity or real estate) and you would like to present money-weighted returns rather than time-weighted returns?
- Does your firm have real estate or private equity composites?
- Does your firm include theoretical performance (e.g., model performance) as part of a GIPS report?
- Does your firm follow the Advertising Guidelines to claim compliance with the GIPS standards outside of your GIPS Reports?
- Does your firm currently update your GIPS compliant presentations more than 12 months after the year ends?
- Does your firm have advisory-only assets or uncalled committed capital you wish to present in your GIPS Report?
Although the intent is for the adoption of the standards to be more relevant, many organizations find themselves asking “where do I even begin?” The great news is that you don’t have to figure this all out on your own.
At Longs Peak, we have spent countless hours familiarizing ourselves with the new standards and have helped all of our clients begin to adopt the changes. We know what issues come up and how to navigate the changes required.
As a consultant, we do not have independence requirements like your verifier, so we can actually help you implement many of the 2020 changes required for your organization. If you do not already work with a GIPS consultant, now may be a good time to consider hiring one, especially if you lack the resources needed to get this done by the deadline to convert to the 2020 GIPS standards.
Contact us if you do not wish to read through all of the requirements and recommendations to identify what actions are required for your organization.
Finally, if you would like to read more about what changed and why, we have summarized the main changes to the GIPS standards in GIPS 2020 What’s Changing and What you Should Do.
Recommended Post
Performance reporting has two common pitfalls: it’s backward-looking, and it often stops at raw returns. A quarterly report might show whether a portfolio beat its benchmark, but it doesn’t always show why or whether the results are sustainable. By layering in risk-adjusted performance measures—and using them in a structured feedback loop—firms can move beyond reporting history to actively improving the future.
Why a Feedback Loop Matters
Clients, boards, and oversight committees want more than historical returns. They want to know whether:
· performance was delivered consistently,
· risk was managed responsibly, and
· the process driving results is repeatable.
A feedback loop helps firms:
· define expectations up front instead of rationalizing results after the fact,
· monitor performance relative to objective appraisal measures,
· diagnose whether results are consistent with the manager’s stated mandate, and
· adjust course in real time so tomorrow’s outcomes improve.
With the right discipline, performance reporting shifts from a record of the past toa tool for shaping the future.
Step 1: Define the Measures in Advance
A useful feedback loop begins with clear definitions of success. Just as businesses set key performance indicators (KPIs) before evaluating outcomes, portfolio managers should define their performance and risk statistics in advance, along with expectations for how those measures should look if the strategy is working as intended.
One way to make this tangible is by creating a Performance Scorecard. The scorecard sets out pre-determined goals with specific targets for the chosen measures. At the end of the performance period, the manager completes the scorecard by comparing actual outcomes against those targets. This creates a clear, documented record of where the strategy succeeded and where it fell short.
Some of the most effective appraisal measures to include on a scorecard are:
· Jensen’s Alpha: Did the manager generate returns beyond what would be expected for the level of market risk (beta) taken?
· Sharpe Ratio: Were returns earned efficiently relative to volatility?
· Max Drawdown: If the strategy claims downside protection, did the worst loss align with that promise?
· Up- and Down-Market Capture Ratios: Did the strategy deliver the participation levels in up and down markets that were expected?
By setting these expectations up front in a scorecard, firms create a benchmark for accountability. After the performance period, results can be compared to those preset goals, and any shortfalls can be dissected to understand why they occurred.
Step 2: Create Accountability Through Reflection
This structured comparison between expected vs. actual results is the heart of the feedback loop.
If the Sharpe Ratio is lower than expected, was excess risk taken unintentionally? If the Downside Capture Ratio is higher than promised, did the strategy really offer the protection it claimed?
The key is not just to measure, but to reflect. Managers should ask:
· Were deviations intentional or unintentional?
· Were they the result of security selection, risk underestimation, or process drift?
· Do changes need to be made to avoid repeating the same shortfall next period?
The scorecard provides a simple framework for this reflection, turning appraisal statistics into active learning tools rather than static reporting figures.
Step 3: Monitor, Diagnose, Adjust
With preset measures in place, the loop becomes an ongoing process:
1. Review results against the expectations that were defined in advance.
2. Flag deviations using alpha, Sharpe, drawdown, and capture ratios.
3. Discuss root causes—intentional, structural, or concerning.
4. Refine the investment process to avoid repeating the same shortcomings.
This approach ensures that managers don’t just record results—they use them to refine their craft. The scorecard becomes the record of this process, creating continuity over multiple periods.
Step 4: Apply the Feedback Loop Broadly
When applied consistently, appraisal measures—and the scorecards built around them—support more than internal evaluation. They can be used for:
· Manager oversight: Boards and trustees see whether results matched stated goals.
· Incentive design: Bonus structures tied to pre-defined risk-adjusted outcomes.
· Governance and compliance: Demonstrating accountability with clear, documented processes.
How Longs Peak Can Help
At Longs Peak, we help firms move beyond static reporting by building feedback loops rooted in performance appraisal. We:
· Define meaningful performance and risk measures tailored to each strategy.
· Help managers set pre-determined expectations for those measures and build them into a scorecard.
· Calculate and interpret statistics such as alpha, Sharpe, drawdowns, and capture ratios.
· Facilitate reflection sessions so results are compared to goals and lessons are turned into process improvements.
· Provide governance support to ensure documentation and accountability.
The result is a sustainable process that keeps strategies aligned, disciplined, and credible.
Closing Thought
Markets will always fluctuate. But firms that treat performance as a feedback loop—nota static report—build resilience, discipline, and trust.
A well-structured scorecard ensures that performance data isn’t just about yesterday’s story. When used as feedback, it becomes a roadmap for tomorrow.
Need help creating a Performance Scorecard? Reach out if you want us to help you create more accountability today!
When you're responsible for overseeing the performance of an endowment or public pension fund, one of the most critical tools at your disposal is the benchmark. But not just any benchmark—a meaningful one, designed with intention and aligned with your Investment Policy Statement(IPS). Benchmarks aren’t just numbers to report alongside returns; they represent the performance your total fund should have delivered if your strategic targets were passively implemented.
And yet, many asset owners still find themselves working with benchmarks that don’t quite match their objectives—either too generic, too simplified, or misaligned with how the total fund is structured. Let’s walkthrough how to build more effective benchmarks that reflect your IPS and support better performance oversight.
Start with the Policy: Your IPS Should Guide Benchmark Construction
Your IPS is more than a governance document—it is the road map that sets strategic asset allocation targets for the fund. Whether you're allocating 50% to public equity or 15% to private equity, each target signals an intentional risk/return decision. Your benchmark should be built to evaluate how well each segment of the total fund performed.
The key is to assign a benchmark to each asset class and sub-asset class listed in your IPS. This allows for layered performance analysis—at the individual sub-asset class level (such as large cap public equity), at the broader asset class level (like total public equity), and ultimately rolled up at the Total Fund level. When benchmarks reflect the same weights and structure as the strategic targets in your IPS, you can assess how tactical shifts in weights and active management within each segment are adding or detracting value.
Use Trusted Public Indexes for Liquid Assets
For traditional, liquid assets—like public equities and fixed income—benchmarking is straightforward. Widely recognized indexes like the S&P 500, MSCI ACWI, or Bloomberg U.S. Aggregate Bond Index are generally appropriate and provide a reasonable passive alternative against which to measure active strategies managed using a similar pool of investments as the index.
These benchmarks are also calculated using time-weighted returns (TWR), which strip out the impact of cash flows—ideal for evaluating manager skill. When each component of your total fund has a TWR-based benchmark, they can all be rolled up into a total fund benchmark with consistency and clarity.
Think Beyond the Index for Private Markets
Where benchmarking gets tricky is in illiquid or asset classes like private equity, real estate, or private credit. These don’t have public market indexes since they are private market investments, so you need a proxy that still supports a fair evaluation.
Some organizations use a peer group as the benchmark, but another approach is to use an annualized public market index plus a premium. For example, you might use the 7-year annualized return of the Russell 2000(lagged by 3 months) plus a 3% premium to account for illiquidity and risk.
Using the 7-year average rather than the current period return removes the public market volatility for the period that may not be as relevant for the private market comparison. The 3-month lag is used if your private asset valuations are updated when received rather than posted back to the valuation date. The purpose of the 3% premium (or whatever you decide is appropriate) is to account for the excess return you expect to receive from private investments above public markets to make the liquidity risk worthwhile.
By building in this hurdle, you create a reasonable, transparent benchmark that enables your board to ask: Is our private markets portfolio delivering enough excess return to justify the added risk and reduced liquidity?
Roll It All Up: Aggregated Benchmarks for Total Fund Oversight
Once you have individual benchmarks for each segment of the total fund, the next step is to aggregate them—using the strategic asset allocation weights from your IPS—to form a custom blended total fund benchmark.
This approach provides several advantages:
- You can evaluate performance at both the micro (asset class) and macro (total fund) level.
- You gain insight into where active management is adding value—and where it isn’t.
- You ensure alignment between your strategic policy decisions and how performance is being measured.
For example, if your IPS targets 50% to public equities split among large-, mid-, and small-cap stocks, you can create a blended equity benchmark that reflects those sub-asset class allocations, and then roll it up into your total fund benchmark. Rebalancing of the blends should match there balancing frequency of the total fund.
What If There's No Market Benchmark?
In some cases, especially for highly customized or opportunistic strategies like hedge funds, there simply may not be a meaningful market index to use as a benchmark. In these cases, it is important to consider what hurdle would indicate success for this segment of the total fund. Examples of what some asset owners use include:
- CPI + Premium – a simple inflation-based hurdle
- Absolute return targets – such as a flat 7% annually
- Total Fund return for the asset class – not helpful for evaluating the performance of this segment, but still useful for aggregation to create the total fund benchmark
While these aren’t perfect, they still serve an important function: they allow performance to be rolled into a total fund benchmark, even if the asset class itself is difficult to benchmark directly.
The Bottom Line: Better Benchmarks, Better Oversight
For public pension boards and endowment committees, benchmarks are essential for effective fiduciary oversight. A well-designed benchmark framework:
- Reflects your strategic intent
- Provides fair, consistent measurement of manager performance
- Supports clear communication with stakeholders
At Longs Peak Advisory Services, we’ve worked with asset owners around the globe to develop custom benchmarking frameworks that align with their policies and support meaningful performance evaluation. If you’re unsure whether your current benchmarks are doing your IPS justice, we’re hereto help you refine them.
Want to dig deeper? Let’s talk about how to tailor a benchmark framework that’s right for your total fund—and your fiduciary responsibilities. Reach out to us today.
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Valuation Timing for Illiquid Investments
Explore how firms & asset owners can balance accuracy & timeliness in performance reporting for illiquid investments.
June 23, 2025
15 min
For asset owners and investment firms managing private equity, real estate, or other illiquid assets, one of the most persistent challenges in performance reporting is determining the right approach to valuation timing. Accurate performance results are essential, but delays in receiving valuations can create friction with timely reporting goals. How can firms strike the right balance?
At Longs Peak Advisory Services, we’ve worked with hundreds of investment firms and asset owners globally to help them present meaningful, transparent performance results. When it comes to illiquid investments, the trade-offs and decisions surrounding valuation timing can have a significant impact—not just on performance accuracy, but also on how trustworthy and comparable the results appear to stakeholders.
Why Valuation Timing Matters
Illiquid investments are inherently different from their liquid counterparts. While publicly traded securities can be valued in real-time with market prices, private equity and real estate investments often report with a delay—sometimes months after quarter-end.
This delay creates a reporting dilemma: Should firms wait for final valuations to ensure accurate performance, or should they push ahead with estimates or lagged valuations to meet internal or external deadlines?
It’s a familiar struggle for investment teams and performance professionals. On one hand, accuracy supports sound decision-making and stakeholder trust. On the other, reporting delays can hinder communication with boards, consultants, and beneficiaries—particularly for asset owners like endowments and public pension plans that follow strict reporting cycles.
Common Approaches to Delayed Valuations
For strategies involving private equity, real estate, or other illiquid holdings, receiving valuations weeks—or even months—after quarter-end is the norm rather than the exception. To deal with this lag, investment organizations typically adopt one of two approaches to incorporate valuations into performance reporting: backdating valuations or lagging valuations. Each has benefits and drawbacks, and the choice between them often comes down to a trade-off between accuracy and timeliness.
1. Backdating Valuations
In the backdating approach, once a valuation is received—say, a March 31 valuation that arrives in mid-June—it is recorded as of March 31, the actual valuation date. This ensures that performance reports reflect economic activity during the appropriate time period, regardless of when the data became available.
Pros:
- Accuracy: Provides the most accurate snapshot of asset values and portfolio performance for the period being reported.
- Integrity: Maintains alignment between valuation dates and the underlying activity in the portfolio, which is particularly important for internal analysis or for investment committees wanting to evaluate manager decisions during specific market environments.
Cons:
- Delayed Reporting: Final performance for the quarter may be delayed by 4–6 weeks or more, depending on how long it takes to receive valuations.
- Stakeholder Frustration: Boards, consultants, and beneficiaries may grow frustrated if they cannot access updated reports in a timely manner, especially if performance data is tied to compensation decisions, audit deadlines, or public disclosures.
When It's Useful:
- When transparency and accuracy are prioritized over speed—e.g., in annual audited performance reports or regulatory filings.
- For internal purposes where precise attribution and alignment with economic events are critical, such as evaluating decision-making during periods of market volatility.
2. Lagged Valuations
With the lagged approach, firms recognize delayed valuations in the subsequent reporting period. Using the same example: if the March 31valuation is received in June, it is instead recorded as of June 30. In this case, the performance effect of the Q1 activity is pushed into Q2’sreporting.
Pros:
- Faster Reporting: Performance reports can be completed shortly after quarter-end, meeting board, stakeholder, and regulatory timelines.
- Operational Efficiency: Teams aren’t held up by a few delayed valuations, allowing them to close the books and move on to other tasks.
Cons:
- Reduced Accuracy: Performance reported for Q2 includes valuation changes that actually occurred in Q1, misaligning performance with the period in which it was earned.
- Misinterpretation Risk: If users are unaware of the lag, they may misattribute results to the wrong quarter, leading to flawed conclusions about manager skill or market behavior.
When It's Useful:
- When quarterly reporting deadlines must be met (e.g., trustee meetings, consultant updates).
- In environments where consistency and speed are prioritized, and the lag can be adequately disclosed and understood by users.
Choosing the Right Approach (and Sticking with It)
Both approaches are acceptable from a compliance and reporting perspective. However, the key lies in consistency.
Once an organization adopts an approach—whether back dating or lagging—it should be applied across all periods, portfolios, and asset classes. Inconsistent application opens the door to performance manipulation(or the appearance of it), where results might look better simply because a valuation was timed differently.
This kind of inconsistency can erode trust with boards, auditors and other stakeholders. Worse, it could raise red flags in a regulatory review or third-party verification.
Disclose, Disclose, Disclose
Regardless of the method you use, full transparency in reporting is essential. If you’re lagging valuations by a quarter, clearly state that in your disclosures. If you change methodologies at any point—perhaps transitioning from lagged to backdated—explain when and why that change occurred.
Clear disclosures help users of your reports—whether board members, beneficiaries, auditors, or consultants—understand how performance was calculated. It allows them to assess the results in context and make informed decisions based on the data.
Aligning Benchmarks with Valuation Timing
One important detail that’s often overlooked: your benchmark data should follow the same valuation timing as your portfolio.
If your private equity or real estate portfolio is lagged by a quarter, but your benchmark is not, your performance comparison becomes flawed. The timing mismatch can mislead stakeholders into believing the strategy outperformed or underperformed, simply due to misaligned reporting periods.
To ensure a fair and meaningful comparison, always apply your valuation timing method consistently across both your portfolio and benchmark data.
Building Trust Through Transparency
Valuation timing is a technical, often behind-the-scenes issue—but it plays a crucial role in how your investment results are perceived. Boards and stakeholders rely on accurate, timely, and understandable performance reporting to make decisions that impact beneficiaries, employees, and communities.
By taking the time to document your valuation policy, apply it consistently, and disclose it clearly, you are reinforcing your organization’s commitment to integrity and transparency. And in a world where scrutiny of investment performance is only increasing, that commitment can be just as valuable as the numbers themselves.
Need help defining your valuation timing policy or aligning performance reporting practices with industry standards?
Longs Peak Advisory Services specializes in helping investment firms and asset owners simplify their performance processes, maintain compliance, and build trust through transparent reporting. Contact us to learn how we can support your team.
