ColoradoBiz Names Longs Peak’s Jocelyn Gilligan, CFA, CIPM as a Gen XYZ Top Young Professional

Longs Peak is pleased to announce that Partner and Co-Founder, Jocelyn Gilligan has been named a GenXYZ Top Young Professional by ColoradoBiz Magazine.
As ColoradoBiz states, “They’re uncommon achievers, whether as entrepreneurs, CEOs, nonprofit leaders, visionaries critical to their companies’ success or, in some cases, all of those roles. This year’s Top 25 Young Professionals figure to continue making a difference professionally and in their communities for years to come.”
Jocelyn grew up in Boulder, CO and graduated from the University of Colorado. She started her career at Ernst & Young in New York City where she worked on their Financial Services Transfer Pricing Team. She transferred with EY to their office in Shanghai and then eventually to Hong Kong. Jocelyn left EY as a Manager and relocated back to Colorado where she and her husband started a family. Soon thereafter, Jocelyn and Sean founded Longs Peak out of a small one-car garage in their home in Longmont, CO. Now running a thriving team of 14, Jocelyn has weathered the ups and downs of entrepreneurship. She credits a lot of their success to their amazing team and the community of entrepreneurs they live near and network with (Longs Peak is an active member of EO (Entrepreneurs Organization)).
Jocelyn is a voting member of the PTO at her children’s school and a member of Women in Investment Performance Measurement, a group recently founded to support women in the investment performance industry.
About ColoradoBiz’s Top 25 Young Professionals
The 13th annual Gen XYZ awards is open to those under 40 who live and work in Colorado — numbered in the hundreds, making for difficult decisions and conversations among judges, as always. Applications were judged by our editorial board based on career achievement, community engagement and their stories of how they got to where they are now.
About Longs Peak
Longs Peak is a purpose and values-driven company. It is our mission to make investment performance information more transparent and reliable—empowering investors to make better, more informed investment decisions.
At the onset, we were looking to help smaller investment managers by giving them access to professional performance experts and tools typically only available to very large firms. We know that our work enables emerging managers to compete with the big guys and helps facilitate their growth. We strive to be our clients’ most valued outsource partner and to be known for our exceptional client service. We know that providing exceptional client service means that we must first create a culture that lives by the ideals we are trying to create for our clients. A place where incredibly talented individuals are empowered to put their best work into the hands of clients that truly value what we do. As a firm, we recognize that our greatest asset is people – both those we work with and those we work for. We continue to evolve into something that represents the needs of both of these groups and hope someday a GIPS Report is provided to every prospective investor in the world.
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As the year draws to a close, we can’t help but marvel at the whirlwind of activities and achievements that have marked 2023 for Longs Peak. Not only have we continued to provide outstanding professional services to our clients, but our team has also celebrated significant personal milestones and accomplished impressive feats. Join us in recapping the memorable moments that shaped our year in this edition of “Around the Peak”.
Celebrations and New Beginnings
Love was in the air at Longs Peak this year with not one, but three major life events. James Blazer and his fiancé Melanie became engaged, Cameron Payseno and Kelsey celebrated their union in a beautiful wedding here in Denver, and anticipation fills the air as Matt Deatherage prepares to welcome his first child likely before the end of the year. These joyous occasions have not only strengthened our bonds, but have also added an extra layer of happiness to our close-knit Longs Peak family as we #LiveOurBestLife.
In addition, our founder, Sean Gilligan celebrated the 10th and 20th anniversaries of his two open heart surgeries, inspiring us to remember that the human spirit, much like the heart, is resilient, enduring, and capable of soaring to new heights even in the face of adversity.
Educational Triumphs
Longs Peak takes pride in the continuous growth and development of its team members. In 2023, Mila Gao and Sara Celapino achieved a significant milestone by passing their CFA Level 1 exam. These accomplishments reflect our commitment to excellence and the continuous pursuit of knowledge within our organization.
Internally, our team – under Matt Deatherage’s tutelage – developed a robust training program for all employees. One of our favorite training sessions this year was spearheaded by our in-house Excel wizard, Henry Jones, who writes formulas while he sleeps and makes everything he touches more efficient.
Global Engagements and Industry Recognition
Our team members Matt, Sean and Cameron showcased their expertise on the international stage, presenting and #SimplfyingTheComplex to five CFA societies across the globe, including Greece, Brazil, and the UK. Domestically, our presence was felt at four conferences, including PMAR North America, the inaugural Women in Performance Measurement (WiPM) Conference, the 27th Annual GIPS Standards Conference, and the ComplyConnect Conference and Expo. Jocelyn also moderated a virtual WiPM panel discussion on performance measurement outside the US while Matt shared his insights at the PMAR Conference, participating in a panel on Performance Reporting; Beyond the GIPS standards #UsePrudentJudgement.
Jocelyn was honored with the Outstanding Women in Performance & Risk Measurement award by the Journal of Performance Measurement. Additionally, Jocelyn’s inclusion in ColoradoBiz magazine’s list of Top 25 Young Professionals in Colorado underscored our team’s dedication, impact, and ability to #ActWithIntegrity.
In addition, Jocelyn is using her financial expertise to serve on the Board of Directors of a Longmont community bank and giving back to our community by serving on the Board of Education and Treasurer for the St. Vrain Valley School District.
Team Growth
Longs Peak expanded its team this year, welcoming Dhwani Desai as an Associate and McKinley Rich as the Director of Operations. These new additions have brought fresh perspectives and expertise to our dynamic team.
For the first time, we have a fully functional internal operations team with Cally Chenault and McKinley Rich at the helm – supercharging the infrastructure and planning for growth in the years to come.
Kelley Cooney earned a well-deserved promotion to the role of Senior Associate, a testament to her outstanding work. We feel fortunate to have her on our team.
Sara Celapino was made a Manager at the end of 2023, in recognition of her remarkable achievements and contributions to Longs Peak. We consider ourselves lucky to have found Sara and remain confident that she will continue to drive our success in the years to come.
As we celebrate the accomplishments of the past year, we also take a moment to acknowledge Cameron Payseno, who marked an impressive five years of #OperatingWithExcellence at Longs Peak. His dedication and contributions have been integral to our success, and we look forward to many more years of collaboration.
Unity in the Mountains
A top highlight of the year was our office retreat in Granby, CO, where the team came together for three days of team-building activities, including a challenging ropes course, bowling, and baking in the breathtaking scenery of the mountains. This retreat reinforced our sense of #BeOneTeam, laying the foundation for continued success in the years to come.
Industry Accolades and Milestones
Longs Peak’s commitment to excellence was acknowledged by ColoradoBiz Magazine, which names us one of the Top 200 Privately Owned Companies in Colorado.
As we bid farewell to 2023, we carry with us a sense of pride for the accomplishments, growth, and moments of joy that have defined this year. Looking ahead, we remain committed to delivering exceptional service, fostering professional development, and building on the strong foundation that has made Longs Peak a leader in the industry.
Cheers to a 2024 that is filled with even more excitement and triumphs!

Today, September 3, 2023, marks Longs Peak's 8th anniversary, and I couldn't be more grateful for the incredible journey we've had over the last 8 years. As we celebrate this milestone, I'd like to reflect on what this date means to me each year, both personally and professionally, and how I've embraced it to live my best life (one of our core values at Longs Peak).
In 8 years, I am proud to say that we have served over 250 investment firms, providing them with consulting services related to calculating and presenting their investment performance. Many of these firms achieved GIPS compliance for the first time with our assistance, allowing us to live out our mission of making investment performance more transparent and reliable – empowering investors to make better, more informed investment decisions.

Our growing team is a testament to the power of teamwork as we focus on this shared vision. The growth we have experienced is not just in numbers but also in our commitment to make a difference in the investment community. As we continue to grow, we remain steadfast in our belief that, together, we can overcome challenges, reach new heights, and inspire others to join us on this journey.
But beyond the business achievements, this date holds a profound personal significance for me. On September 3, 2003, exactly 20 years ago, I underwent my first open heart surgery to repair an aortic aneurysm and receive an aortic valve from a pig. A decade later, on September 3, 2013, I underwent my second open heart surgery to replace the pig valve with one from a cow, as the pig valve had torn.
Facing these challenging surgeries and the recovery periods was undoubtedly difficult, but I made a conscious decision to embrace a positive outlook on life. I chose to see myself as a survivor, part farm animal or not, and this mindset inspired me to live life to its fullest. For me, that meant taking bold chances and not letting fear hold me back from pursuing my dreams.
One of the most significant risks I took was starting Longs Peak with my wife, Jocelyn. At that time, we had two babies and no other income. That giant leap led to so much more and although there have been times of fear (like trying to scale a business through a pandemic!), it has been an immensely rewarding adventure, all thanks to our incredible clients and team.
This approach to life has also pushed me to make decisions that go beyond work. Each year, on or around September 3rd, I celebrate my life and health by doing something that I wouldn't have been able to do without the success of those surgeries. In the past, I've run marathons, completed long hikes, and climbed 14ers (mountains with peaks higher than 14,000 feet) in Colorado and even summitted Mount Kilimanjaro in Tanzania. This year, I am grateful to spend this anniversary hiking La Plata Peak (Colorado’s 5th highest mountain) with Jocelyn followed by a trip with my brother to Slovakia to hike the High Tatras.
On this special day, I am reminded of how precious life is. By seizing opportunities and pushing myself to new heights, I've discovered the true meaning of living my best life. This year, as we mark both the 10th and 20th anniversaries of my surgeries (and 8th anniversary of Longs Peak), I wanted to take a moment to thank some key players in my life that have inspired me along the way.
To my parents, thanks for raising me with an entrepreneurial spirit. Growing up with a paper route, mowing lawns, and shoveling driveways taught me more about starting and running a business than anything I learned in school. I also appreciate your encouragement and support along the way!
To my brother, the time we both spent living in New York in our 20’s was transformational for me. Coming from a small town, I never would have moved to New York if you weren’t already there clearing the way. I learned so much in those years both from you and from the invaluable work experience I gained there early in my career. That experience and time we spent together really changed the course of my life and career and I owe a lot of that to you.
To my wife, thanks for always being up for an adventure! In 2009, shortly after we got married, I suggested we leave New York and move to Shanghai for an amazing work opportunity and you said, “let’s do it!” In 2015 I suggested that I quit my job and we start Longs Peak together and you said, “let’s do it!” In 2019 I suggested we have a 4th baby and you said, “let’s do it!” You make life fun. I appreciate your optimism and the faith you have in us. Most of all, I appreciate the way you always show up 100% for our family, team, clients, and anyone else who needs you. We love you!
To my kids, thanks for putting up with me and mom talking about work all the time and for patiently riding the entrepreneurial rollercoaster with us! One of the reasons we started our business was so we could work from home and be close to you all before working at home was as common as it is now. I may not always love it in the moment when you walk in on an important video call to ask an urgent question, like if you can have a snack, but I know I will love looking back on memories like that someday. You all are my inspiration for everything I do. Whether it is the things I do to improve my health or career, I am motivated to do it imagining the long healthy future I want to enjoy together with all of you.
To our team, who we affectionately refer to as our “big kids,” we appreciate everything you do to make Longs Peak the best it can be. All of you embody our core values and that shines through in how each of you approach the exceptional service we strive to provide to our clients. At the same time, you make Longs Peak an enjoyable place for me to work every day. I truly appreciate that and am grateful to each and every one of you.
To our clients, thank you for entrusting us with the opportunity to assist in projects that we hope have led you to further growth and success. Your confidence in our expertise fuels our commitment to delivering exceptional service and innovation. Your GIPS and performance objectives are the driving force behind our growth. We are genuinely honored to be a part of your journey to grow your firm.
To everyone, I would not be where I am today without your influence and support in my life. You have inspired me to do everything I can to live my best life. I hope everyone reading this takes the opportunities presented to them to take calculated risks (pun intended) and live life to its fullest. Thank you all - I look forward to the many more adventures yet to come!
Longs Peak is pleased to announce that Partner and Co-Founder, Jocelyn Gilligan has been named a GenXYZ Top Young Professional by ColoradoBiz Magazine.
As ColoradoBiz states, “They’re uncommon achievers, whether as entrepreneurs, CEOs, nonprofit leaders, visionaries critical to their companies’ success or, in some cases, all of those roles. This year’s Top 25 Young Professionals figure to continue making a difference professionally and in their communities for years to come.”
Jocelyn grew up in Boulder, CO and graduated from the University of Colorado. She started her career at Ernst & Young in New York City where she worked on their Financial Services Transfer Pricing Team. She transferred with EY to their office in Shanghai and then eventually to Hong Kong. Jocelyn left EY as a Manager and relocated back to Colorado where she and her husband started a family. Soon thereafter, Jocelyn and Sean founded Longs Peak out of a small one-car garage in their home in Longmont, CO. Now running a thriving team of 14, Jocelyn has weathered the ups and downs of entrepreneurship. She credits a lot of their success to their amazing team and the community of entrepreneurs they live near and network with (Longs Peak is an active member of EO (Entrepreneurs Organization)).
Jocelyn is a voting member of the PTO at her children’s school and a member of Women in Investment Performance Measurement, a group recently founded to support women in the investment performance industry.
About ColoradoBiz’s Top 25 Young Professionals
The 13th annual Gen XYZ awards is open to those under 40 who live and work in Colorado — numbered in the hundreds, making for difficult decisions and conversations among judges, as always. Applications were judged by our editorial board based on career achievement, community engagement and their stories of how they got to where they are now.
About Longs Peak
Longs Peak is a purpose and values-driven company. It is our mission to make investment performance information more transparent and reliable—empowering investors to make better, more informed investment decisions.
At the onset, we were looking to help smaller investment managers by giving them access to professional performance experts and tools typically only available to very large firms. We know that our work enables emerging managers to compete with the big guys and helps facilitate their growth. We strive to be our clients’ most valued outsource partner and to be known for our exceptional client service. We know that providing exceptional client service means that we must first create a culture that lives by the ideals we are trying to create for our clients. A place where incredibly talented individuals are empowered to put their best work into the hands of clients that truly value what we do. As a firm, we recognize that our greatest asset is people – both those we work with and those we work for. We continue to evolve into something that represents the needs of both of these groups and hope someday a GIPS Report is provided to every prospective investor in the world.
LONGMONT, Colorado, January 12, 2022 – Longs Peak Advisory Services, LLC (“Longs Peak”) announced today that the company has appointed Matthew Deatherage, CFA, CIPM as equity Partner, effective January 1, 2022.
Mr. Deatherage has over 8 years of experience specifically in GIPS and Investment performance and has worked with some of the world’s largest financial institutions to help them with their GIPS compliance. Before being promoted, Matt served as a Senior Manager and member of Longs Peak’s Executive Team. In this role, he was responsible for developing the company’s Client Experience, Training & Development, and Quality Control processes. In addition, Matt spearheads Longs Peak’s Alternative Asset Management GIPS projects. Since joining, Matt has helped the company nearly double the number of clients we serve. Prior to working at Longs Peak, Matt worked for ACA Compliance Group and Ashland Partners.
“I am honored to be made Partner," said Matt. "In my experience with the company, I’ve developed a deep appreciation for what makes Longs Peak so special. Longs Peak’s success is rooted in the team we have built and the customers we serve. I believe we have so much opportunity to capitalize on this foundation, innovate for the future and continue to grow. I look forward to continuing to work with our global client base and growing team to deliver on our goal to simplify how investment firms calculate and present investment performance."
“We have all been impressed by Matt’s leadership and track record of operating with excellence, executing on client engagements and cultivating a team that drives results. Matt has consistently delivered on building our client relationships and our team’s expertise,” said Jocelyn Gilligan, CFA, CIPM, Partner. “Longs Peak wouldn’t be the same without him.”
“Since meeting Matt almost a decade ago when we both worked for a large GIPS verification firm, I knew he had a lot of potential,” said Sean Gilligan, CFA, CPA, CIPM, Managing Partner. “His experience and ambition add a ton of value to our clients and our firm. The entire Longs Peak team is excited about his promotion as we all benefit so much from his leadership and technical expertise. We know he has the drive to help bring Longs Peak and our clients into a new chapter of growth and success.”
About Longs Peak
Longs Peak Advisory Services, LLC is a consulting firm specialized in helping investment firms and asset owners calculate and present investment performance. Longs Peak has worked with over 170 firms across North America, Europe, and Asia since its inception in 2015 to help them calculate and present investment performance or comply with the GIPS Standards.
Contact
Longs Peak
Matt Deatherage, CFA, CIPM
Related Links:
https://longspeakadvisory.com/
Today, September 3, 2018, Longs Peak turns 3 years old! Over the last 3 years we have provided investment performance and GIPS consulting services to over 70 investment firms and we are proud that, for many of these firms, we helped them claim compliance with the GIPS standards for the first time.
To celebrate this occasion, instead of writing a technical blog about performance and GIPS, I’d like to share what this date means to me each year.
September 3rd was not an arbitrary date to launch our firm. This date is significant to me because on September 3rd 2003 I had my first open heart surgery to repair an aortic aneurysm and to replace my aortic valve with a valve from a pig. Exactly ten years later, on September 3rd 2013, I had a second open heart surgery to replace my pig valve with a valve from a cow because my pig valve had torn.
Going through these surgeries and the recovery periods that followed was not easy, but I made a conscious decision to embrace being part farm animal and focus on the positive. These experiences motivated me to live my life to its fullest potential. This means something different to everyone, but for me, this meant taking chances to ensure I didn’t look back on my life wishing I’d had the courage to do something I was too scared to try. One of the biggest chances I took was leaving a great job to start Longs Peak. This was one of the scariest decisions I’ve ever made, but it has been one of the most rewarding adventures of my life, thanks to our wonderful clients and amazing team.
Over the years, this mentality has pushed to make decisions that help me truly experience life outside of work as well. Specifically, on or around September 3rd each year, I celebrate my life and health by doing something I would not have been able to do if it weren’t for the success of these surgeries. In previous years I have run a marathon, completed long hikes, and climbed 14ers (mountains in Colorado above 14,000 feet), but this year I am taking it to a new level!
With this year being both the 5th and 15th anniversaries of my two surgeries, I was looking for a big physical challenge as well as a way to encourage the people around me to live long, healthy, and satisfying lives. This year, I have decided to climb Mount Kilimanjaro as a fundraiser for the American Heart Association, which I will do during the second half of this month.

The American Heart Association’s mission is to be a relentless force for a world of longer, healthier lives. Without the hard work of organizations like this, the idea of putting parts of farm animals into people would sound ridiculous. Actually, it still does sound ridiculous, but it works, and it gives people like me the opportunity to live full and complete lives.
I would love to have your support in this adventure. If you are interested in contributing to the fundraiser, donations of any amount are greatly appreciated and can be made through the link below. Please note that as my contribution to this cause I will personally match all donations up to $2,500.
Link to fundraiser page: Gilly Does Kili
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If you manage money for institutional clients, you've probably heard some version of this sentence: "We can't consider your strategy unless you're GIPS compliant." For a lot of investment managers, that's the moment the Global Investment Performance Standards (GIPS®) stop being an abstract industry term and start being a business requirement.
This guide covers what GIPS compliance actually is, who needs it, what it takes to get there, and how to keep it running once you do. Wherever a topic deserves a deeper dive, we've linked to the longer article that covers it. Think of this as the map, with the detailed trail guides linked along the way.
What Is GIPS Compliance?
GIPS compliance means a firm calculates and presents its investment performance according to the GIPS which is a set of ethical, standardized rules for performance reporting created and administered by CFA Institute. At their core, the GIPS standards rest on two principles: fair representation and full disclosure.
In practice, that means a GIPS compliant firm can't cherry-pick its best-performing accounts to show a prospect. It has to group similar portfolios into composites, present the full history honestly, disclose the assumptions behind the numbers, and apply the same rules consistently across the entire firm.
GIPS compliance is voluntary. No regulator requires it. But it has become the closest thing the investment industry has to a common language for performance. This is often why so many institutional investors, consultants, and platforms require it before they'll even take a meeting.
Who Needs to Be GIPS Compliant?
Any investment manager who wants to compete for institutional business should take GIPS compliance seriously. That includes:
- RIAs and asset managers pursuing institutional mandates (pensions, endowments, foundations, OCIOs)
- Firms seeking placement on model delivery platforms, SMA platforms, or consultant databases
- Managers responding to RFPs where GIPS compliance is a stated requirement
- Firms that simply want a more defensible, standardized way to calculate and present performance — even without external pressure to do so
According to eVestment, roughly two out of three searches run by institutional investors and consultants in their database exclude firms that aren't GIPS compliant. If your strategy to scale your firm includes institutional or consultant-driven channels, GIPS compliance isn't optional in any practical sense, it's the price of admission.
That said, don't mistake GIPS compliance for a purely institutional tool. Even firms with no institutional ambitions benefit from the discipline it offers: consistent calculation methodologies, documented policies, and a defensible and repeatable process for measuring performance. That rigor tends to pay off internally long before a prospect ever asks for it. And every additional firm that complies strengthens the credibility of the standards industry-wide, which benefits compliant firms and investors alike. The question worth asking isn't whether GIPS compliance is relevant to your business, it's whether now is the right time to embark on the path to become GIPS compliant.
(Note: this guide focuses on investment managers. If you're an asset owner — a pension, endowment, or foundation — evaluating your own internal performance reporting, our asset owner GIPS compliance page covers considerations specific to that role.)
Is GIPS Compliance Required?
No. GIPS compliance is a voluntary standard, not a law or regulation, and the SEC doesn't require it. That part isn't where firms gettripped up.
What's worth understanding is how close many firms already are to GIPS compliance without ever setting out to pursue it. The SEC Marketing Rule requires advertised performance to be fair and balanced, substantiated, and — in most cases — presented net of fees. Those requirements weren't written to mirror the GIPS standards, but in practice they've pushed firms toward much of the same discipline: consistent calculation methodology, defensible net-of-fee treatment, and documentation that can withstand scrutiny.
That means a lot of SEC-registered advisers may already have some of the infrastructure GIPS compliance requires before they've ever considered pursuing it formally. If you're already calculating net returns consistently, applying one methodology across accounts rather than picking whatever looks best, and keeping documentation to back up what you advertise, the remaining work (constructing composites, writing the GIPS standards policies and procedures, and assembling GIPS Reports) is often a smaller lift than firms assume, especially if you hire a consultant like Longs Peak to help!
The frameworks aren't identical, and there are places where they diverge. The GIPS standards permit either gross- or net-of-fee presentation, while the SEC Marketing Rule requires net returns whenever gross is shown; when local law or regulation is stricter than the GIPS standards, firms follow the stricter rule and disclose the deviation. We've written a full breakdown of how that reconciliation works, including sample disclosure language, in Navigating GIPS Compliance When Local Laws Conflict. But those are details to reconcile, not reasons to start from scratch.
How to Become GIPS Compliant: The Building Blocks
GIPS compliance rests on four core components, and implementation generally means building them in this order.
1. Define the firm and scope the universe of portfolios. Compliance is claimed on a firm-wide basis, never at the composite, product, or portfolio level. Before anything else, a firm must define itself: which legal entities, offices, and business lines are included, and how the firm is held out to the public. This sounds simple but is often the most consequential decision in the entire process, especially for firms with multiple brands or affiliated entities. Once that's settled, inventory every account, pooled fund, and mandate that falls within the definition.
2. Build the GIPS standards policies and procedures manual (the "P&P"). This is the operational rulebook: how discretion is defined, how composites are constructed, how cash flows are handled, how errors get corrected. A strong GIPS standards P&P reflects what the firm actually does, not what looks good on paper. Documenting it now, before it's tested by a real-world edge case, saves a lot of pain later.
3. Construct composites and calculate performance. Discretionary portfolios with similar strategies are grouped into composites so performance is presented at the strategy level rather than as a cherry-picked account or model portfolio. Composite construction is typically where firms spend the most time, since it requires historical data review, judgment calls about discretion, and reconciliation across systems. Then asset-weight returns and calculate the required statistics for at least five years of compliant history(or since inception, if younger).
4. Create GIPS Reports and file the compliance notification. The GIPS Report is the compliant, disclosure-rich presentation of a composite's performance that must be given to every prospective client. It includes required statistics, fee treatment, and disclosures that give context to the numbers. Once GIPS Reports are complete, the firm files the GIPS Compliance Notification Form with CFA Institute, a final required step before compliance can be claimed, and one that must be renewed annually.
5. Verification (optional, but a good idea). An independent third party can test whether a firm's policies and procedures are designed appropriately and applied consistently firm-wide. It's not required, but it's widely expected in institutional circles (more on this below).
We've written a full phase-by-phase walk through, including the judgment calls that tend to trip firms up (like defining discretion and handling historical composite membership), in A Practical Framework for Implementing the GIPS Standards.
How long does this take? For most firms with a simple, straight forward structure, implementation can be complete in less than one month. For moderately complex firms or simple firms with longer track records, implementation often runs somewhere between three and six months from kickoff to a completed GIPS Report. Firms with complex legal structures, long historical track records, or messy underlying data should expect it to take longer. The upfront investment in earlier phases (firm definition and policy development) as well as the commitment from your team is what usually determines the timeline.
How much will it cost? One of the questions we hear most often is "what does it cost to become GIPS compliant?" The honest answer is that it depends on a lot of inputs. Two firms of similar size can land in very different places depending on how many composites and accounts they manage, how many years of history must be reconstructed, how complete existing records are, how clean the underlying data is, and how much back-and-forth it takes to resolve open questions along the way. Because of that, we scope every engagement individually rather than pricing it off a flat rate card. The factors below are the ones that most reliably move the estimate up or down. Thinking through them ahead of time makes for a much more productive first conversation.
What tends to drive cost:
Composites and accounts in scope: How many strategies need to be reported on, and how many underlying accounts roll up into them? Being larger doesn’t always mean it will cost more, but we typically find that more accounts or composites often means more work to determine their proper placement.
Years of history involved: Are you reconstructing several years (or since inception) of past performance or are you a brand-new firm just getting started? This becomes a bigger factor the longer the track record (which is often tied to data quality).
Quality of existing records: How complete and well-organized is your historical composite membership documentation? This is often the biggest swing factor. We regularly see firms come in confident that their data is clean, only to find once we're in the weeds that it isn't. Being honest about this up front, even where the answer is "we're not totally sure," helps the entire engagement team start with the same expectations rather than discovering the real scope midstream.
Verification plans: Do you intend to pursue verification alongside (or shortly after) the buildout? This adds coordination and review on top of the compliance work itself.
Existing GIPS compliance experience: Are you starting from a blank page or do you already have some policies, procedures, or a prior composite performance to build on? The more existing foundation you have, the better.
Responsiveness and internal bandwidth: How quickly will your team turn around data requests and answer questions? This affects the timeline most directly, but slow back-and-forth does add real hours too.
We like to meet firms where they are. That might mean managing the full project or helping with the pieces that are most challenging or resource-intensive. We can usually find a way to add value even when a full-scope engagement doesn’t make sense. It’s also worth keeping in mind that some larger providers of managed services have minimum fees or engagement sizes, which may make them less practical depending on your needs and budget. If you’re still unsure if this is the right time, check out our post The Case for Pursuing GIPS Compliance Before You Think you Need It.
Do You Need to Be Verified? No. Verification is voluntary under the GIPS standards. A firm can claim compliance without ever being verified.
That said, verification is generally worth pursuing, particularly for firms competing for institutional mandates where GIPS compliance is treated as table stakes. Verification provides independent assurance that a firm's policies and procedures are designed in line with the GIPS standards and applied consistently — which carries real weight with consultants and prospects performing due diligence. It also tends to create useful internal discipline, since the expectation of independent review keeps processes tighter throughout the year.
If you're earlier in your compliance journey or working within budget constraints, it's reasonable to build a solid compliance foundation first and pursue verification once the timing makes sense. For a detailed walkthrough of what the process actually involves, see our series, How to Survive a GIPS Verification.
GIPS Compliance and the SEC Marketing Rule
For US-registered investment advisers, GIPS compliance doesn't happen in a vacuum — it has to coexist with the SEC Marketing Rule. The two frameworks overlap in some places (both care about fair, substantiated, non-misleading performance) and diverge in others (fee treatment, required disclosures, what counts as an advertisement).
Firms that manage this well tend to build one governance framework that covers both — rather than treating GIPS compliance and marketing rule compliance as separate workstreams run by different teams. We cover what that coordination looks like in practice, including how GIPS Reports, factsheets, and pitchbooks should stay consistent with each other, in What Good GIPS Compliance Governance Looks Like in Practice.
Common Mistakes Investment Managers Make
After helping firms through this process for over a decade, the same handful of issues come up again and again:
- Treating GIPS compliance as a one-time project. Compliance is a firm-wide standard maintained continuously — not a binder that gets built once and shelved.
- A "department of one." When all GIPS compliance knowledge lives with a single person, the firm is one departure away from a serious continuity problem.
- Policies that don't reflect reality. A GIPS standards P&P that describes an idealized process — rather than what the firm actually does — creates real exposure during verification or a regulatory exam.
- Weak documentation of judgment calls. Decisions about discretion, composite redefinitions, or benchmark changes need a paper trail, not just an outcome.
- Underestimating the data work. Composite construction is as much a data reconciliation exercise as it is a compliance exercise. Firms that skip a thorough historical review often find problems later — usually during verification, which is the most expensive time to find them.
Maintaining Compliance: It Doesn't End at "Go-Live"
Becoming compliant is a milestone. Staying compliant is the actual job. The most common breakdowns aren't dramatic, they're small process gaps that compound: a portfolio added to a composite late, a significant cashflow handled inconsistently, or a new strategy launched without a composite decision being made.
The firms that stay clean build GIPS compliance into their regular monthly or quarterly performance cycle, assign clear ownership, and review their policies at least annually. We go deeper on what strong day-to-day governance looks like, including how to structure oversight without over-engineering it, in What Good GIPS Compliance Governance Looks Like in Practice.
The Business Case for GIPS Compliance
Compliance work rarely gets exciting attention internally, but the payoff is concrete. Firms that pursue GIPS compliance typically gain:
- Access to platforms, consultant databases, and institutional searches that require it as a baseline
- Credibility with allocators who use GIPS compliance as a proxy for operational rigor
- Consistency across performance, marketing, and compliance teams that often didn't exist before
- A cleaner foundation for scalability, since the process tends to surface and fix data issues before they become bigger problems
We've watched this play out directly with clients expanding into model delivery platforms and formalizing composite reporting for the first time. For real examples of how compliance translated into new business relationships, see From Compliance to Growth: How the GIPS Standards Help Investment Firms Unlock New Opportunities.
Frequently Asked Questions
What is GIPS compliance? GIPS compliance means a firm calculates and presents investment performance according to the Global Investment Performance Standards (GIPS®), a voluntary, globally recognized set of ethical standards administered by CFA Institute.
Is GIPS compliance mandatory in the United States? No. It's voluntary. The SEC does not require GIPS compliance, though many institutional investors, consultants, and platforms require it as a practical condition of doing business.
Who administers the GIPS standards? CFA Institute owns and administers the GIPS standards, including the GIPS Handbook, Guidance Statements, and the Q&A database that firms rely on for interpretive guidance.
How long does it take to become GIPS compliant? Most firms with a straightforward structure can complete implementation in three to six months. Firms with complex legal structures, long track records, or significant data cleanup will typically need more time.
What is a GIPS Report? A GIPS Report is the standardized, disclosure-rich presentation of a composite's or pooled fund's performance that a GIPS compliant firm must provide to every prospective client or investor.
Is verification required? No, verification is optional. However, it's widely viewed as a meaningful credibility signal, particularly for firms pursuing institutional business, and many allocators expect it in practice.
Can smaller firms become GIPS compliant? Yes. Firm size doesn't determine eligibility. Smaller firms often benefit from outsourcing implementation and ongoing maintenance to a consultant rather than building an internal GIPS compliance function from scratch.
Does GIPS compliance replace the need to follow the SEC Marketing Rule? No. They're separate obligations. A firm can be GIPS compliant and still need to independently satisfy SEC Marketing Rule requirements, particularly around net-of-fee presentation and substantiation of claims.
How Longs Peak Helps
Becoming and maintaining GIPS compliance touches every part of a firm: performance, operations, compliance, and marketing. That's a lot to coordinate on top of running the business.
At Longs Peak, we specialize in guiding investment managers through the entire journey. We help write policies and procedures, construct and maintain composites, prepare GIPS Reports, and manage the verification process alongside your chosen verifier. We've helped more than 250 firms and asset owners get there, and we stay with our clients well past go-live to keep compliance running smoothly year after year.
If you're weighing whether GIPS compliance makes sense for your firm, or you're already compliant and want a second set of eyes on how it's being maintained, let's talk.
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.

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.

There is a common assumption among boutique investment managers that the Global Investment Performance Standards (GIPS®) are built for the largest firms in the industry — that compliance is something you pursue once you've reached a certain scale, a certain client type, or a certain level of institutional credibility.
That assumption is understandable. And it is costing firms real opportunities.
The GIPS standards have no AUM threshold to get started. There is no minimum number of clients or composites required before a firm can claim compliance. And increasingly, the institutional marketplace is not waiting for firms to reach some undefined moment of readiness before asking for it. If you are newer to the GIPS standards and want a foundation for what they are and why firms pursue them, start with our post What Are the GIPS Standards?
The Market Has Already Decided
The gatekeepers of institutional capital such as consultants, outsourced CIO platforms, model delivery networks, and institutional allocators, have been quietly raising the bar on performance reporting standards for years. GIPS compliance has shifted from a differentiator to a baseline expectation in many of these channels.
According to eVestment, two out of three manager searches conducted by investors and consultants on their platform exclude firms that are not GIPS compliant. That means boutique managers without a compliance claim are not being passed over, they are simply not being seen. As we explored in From Compliance to Growth, GIPS compliance has effectively become the price of admission for firms seeking to expand into institutional channels.
The question is not whether your firm will eventually need it. For most managers with institutional ambitions, the answer to that question is already yes. The real question is when you choose to pursue it, and whether you make that choice on your own terms or in response to a mandate you cannot afford to lose.
What Compliance Actually Builds Inside Your Firm
The benefits most managers focus on are external. Things like the credibility signal, the access to channels, the due diligence box that gets checked. Those benefits are real. But some of the most meaningful returns from GIPS compliance are internal.
Implementing the GIPS standards requires firms to formalize processes that often exist informally. Composite definitions. Discretion criteria. Benchmark selection rationale. Fee policies. Error correction procedures. For many boutique managers, the implementation process is the first time these decisions have been documented and applied consistently across the firm.
That discipline matters beyond GIPS compliance itself. A firm with clean, documented performance infrastructure is better positioned for regulatory examinations, investor due diligence, and operational due diligence reviews. It demonstrates to sophisticated allocators that the firm is run with the same rigor they apply to their own oversight responsibilities. And for firms that are not primarily focused on institutional distribution, this operational foundation has standalone value, the kind of infrastructure that supports sound governance regardless of who is asking. For more on what a well-governed GIPS compliance program looks like once it is in place, see What Good GIPS Compliance Governance Looks Like in Practice.
The Single Best Argument for Starting Now
Here is the point that does not get made often enough: the smaller your firm and the shorter your track record, the easier it is to become compliant. That ratio flips quickly as you grow.
Retroactively constructing composites across a large number of separate accounts is genuinely difficult work, particularly when no framework existed at the time to assign accounts to composites at inception, or to move accounts between composites as investment objectives changed, client restrictions were added or removed, or mandates evolved. Working through that history portfolio by portfolio, period by period, requires both detailed documentation and sound judgment. It is one of the most time-consuming phases of any GIPS compliance implementation, and the complexity compounds with every account and every year of history added.
A firm with 30 separate accounts and a two-year track record faces a very different implementation project than the same firm a few years later with 500 accounts and a five-year track record. The strategy, the clients, and the investment process may be nearly identical, but the administrative burden of reconstructing historical composite membership correctly is not.
The firms that find implementation most manageable are the ones that started before the project grew into something unwieldy. The firms that find it most painful are the ones that waited until an institutional prospect made it urgent.
What if you are not ready to commit to full compliance yet?
That is a legitimate position. But there is a practical middle path worth considering: even if a firm does not want to claim compliance with the GIPS standards today, building out the composite structure and creating policies and procedures for managing those composites now is a worthwhile investment. That framework does not require a formal compliance claim to be useful. Additionally, it can be carried directly into a full GIPS compliance program when the time is right, dramatically reducing the effort required at that stage.
The Real Costs
Becoming GIPS compliant requires real work, and it is worth being direct about what that entails. At a high level, implementation comes down to four phases: defining the firm, building a GIPS standards policies and procedures manual, constructing composites and calculating performance, and creating GIPS Reports with ongoing monitoring controls. We walk through each phase in detail in A Practical Framework for Implementing the GIPS Standards.
In terms of ongoing commitment, firms should expect monthly composite management, annual GIPS Report updates, periodic policies and procedures reviews, and distribution tracking. For a lean team, owning all of this internally is often not realistic. The good news is that outsourcing to a GIPS compliance consultant is a well-established path for boutique managers and one that many firms in our client base have taken successfully. The total cost of compliance for a focused, well-organized firm is frequently lower than managers expect, particularly when implementation is approached while the firm's history and account universe are still manageable.
Is This the Right Time for Your Firm?
Not every firm is at the same point in this decision. Managers with the strongest case for pursuing GIPS compliance now include:
- Firms actively pursuing institutional mandates or seeking coverage from investment consultants
- Managers on model delivery platforms or building toward that distribution channel
- Firms planning meaningful growth over the next two to three years
- Any manager whose clients or prospects have already raised the question
- Firms that simply want to build a best-in-class performance reporting foundation, regardless of where their distribution strategy stands today
The case is lower urgency for firms focused exclusively on high-net-worth or retail clients with no near-term institutional ambitions; however, there is still value in building a sound performance reporting structure, and the sooner it is established, the easier the work will be.
On Verification: You Can Wait
Verification is independent, voluntary, and valuable. It is also not required to claim compliance with the GIPS standards, and for cost-conscious boutiques, it is a reasonable place to exercise flexibility.
A firm can become GIPS compliant today and gain all the operational benefits and the ability to make the compliance claim and defer pursuing verification until there is specific demand for it. When an institutional prospect or consultant asks whether the firm is verified, that is the right moment to add it. The compliance foundation built now makes that future engagement faster and less disruptive. For a detailed walkthrough of what the verification process involves, see our series How to Survive a GIPS Verification.
Verification is worth having. It just does not need to happen on day one.
The Longer You Wait, The Heavier the Lift
GIPS compliance is not an initiative that gets easier with time. Every year a firm grows its account base, extends its track record, and adds complexity to its operations without a compliance framework in place is another year of history that will eventually need to be organized, documented, and reconstructed.
The managers who find implementation most straight forward are not the ones with the most resources. They are the ones who started early enough that the project was still proportionate to the size of the task.
If your firm is headed toward institutional distribution (most boutique managers we work with are), the best time to build this infrastructure is before you need it. The second best time is now.
Longs Peak Advisory Services specializes in GIPS compliance and investment performance consulting for investment managers and asset owners. We have helped over 250 firms implement and maintain compliance with the GIPS standards. If you are evaluating whether now is the right time for your firm, we would be glad to talk through it. Reach out athello@longspeakadvisory.com.
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.



