Key Takeaways from the 2023 PMAR Conference

Sara Celapino
Manager
June 23, 2023
15 min
Key Takeaways from the 2023 PMAR Conference

TSG hosted the 21st annual Performance Measurement, Attribution & Risk (PMAR) North America Conference on May 24th - 25th 2023 in New Brunswick, New Jersey. Longs Peak had the pleasure of sponsoring the event and being represented on the Performance Reporting: Beyond the GIPS standards panel on day 2 of the conference by our very own Matt Deatherage, CFA, CIPM.

With many unanswered questions still circulating on the implementation of the SEC Marketing Rule that took effect last November, there were multiple sessions that touched on this topic. Other topics included ESG and its impact on performance, maximizing the potential of AI, performance evaluation and risk when returns aren’t normally distributed, evaluating benchmark misfit risk, and other hot topics such as talent retention and outsourcing.

With many women in the industry already attending PMAR, the conference also facilitated the first in-person Women in Performance Measurement (WiPM) meeting May 23rd. Longs Peak co-sponsored this event with TSG and sent four members of our team to the event. Interacting with so many brilliant women in different stages of their careers was a great experience, and the women of Longs Peak are looking forward to being part of the continued growth and development of the group.

ESG

ESG reporting requirements are ramping up, coming from pressure from shareholders and employees as well as in response to looming federal climate-disclosure regulations. The trend is no different for prospective investors as interest in ESG information is increasingly being requested by prospects. According to this WSJ article, “Nearly 80% of roughly 400 global institutional investors surveyed last year said companies should make investments that address ESG issues, even if doing so reduces profits in the short term.” The speaker reiterated this sentiment and said although the regulations in the US are behind Europe and Australia, he said that the SEC is getting there.

AI and Machine Learning in Investment Management

It is no secret that large language models (LLMs) like ChatGPT or BloombergGPT are increasingly being incorporated in investment management. LLMs offer powerful technologies that can be utilized for a variety of advancements from data analysis and research to providing valuable insights from financial reports and supporting decision-making. In addition, they can contribute to risk assessment, compliance, and portfolio management by analyzing data and optimizing strategies. It is our opinion that this technology will revolutionize the financial services industry and will do so rapidly.

Of course, the integration of AI and Machine Learning technology comes with advantages and disadvantages. While the technologies offer improved efficiency and accuracy, relying too heavily on this technology can introduce algorithmic biases that can impact investment decisions. As performance experts, we wonder if it will create an overreliance on historical data and as we know, past performance may not always be indicative of future results. Key takeaways from this session were to consider how your firm might utilize LLMs and Machine Learning in your own processes and that while this technology is still somewhat new, it is increasingly accessible to anyone at reasonable cost.

Performance Reporting: Beyond the GIPS Standards

The panel discussed the types and frequency of performance they’re seeing internally and externally. Depending on the asset class, monthly or quarterly external reporting is most common, while some portfolio managers have found value in utilizing daily reporting internally to see how their strategies are performing in real-time. Firms seem to be steering away from manual updates and relying more heavily on automation and external resources for reporting. Beyond the statistics required by the SEC, including visuals in their reports was touched on by the panel as well as focusing on the story the firm is looking to tell based on the goals of the specific strategy.

Firms distributing performance also need to consider the internal controls needed to ensure that they are presenting accurate performance relevant to the specific audience. The importance of audit logs and extensive internal review was stressed, and firms are constantly looking for ways to improve these processes and save time. These challenges extend to updating databases in a timely and efficient manner, with some firms opting to upload preliminary performance to meet database deadlines and then making retrospective changes as needed.

While Excel is still king in the performance world, utilizing performance systems for calculation and reporting can create efficiencies and reduce opportunity for manual error. Flexibility is key, as end users want to be able to customize reporting for their specific needs. The ultimate reporting goal for many firms seems to be aggregating performance and risk statistics from different sources, and firms have found success using dashboards and other technology to simplify these processes.

SEC Insights

With many of our clients being SEC-registered investment firms, we’ve been just as eager as the rest of the industry for additional guidance on the SEC Marketing Rule. Unfortunately, it sounds like it may be a while until additional FAQs are released. One requirement that has raised many questions is the requirement to present performance net-of-fees. “Performance” isn’t defined by the SEC, so the PMAR panel, focused on extracted performance and attribution, attempted to shed some light on what could be considered performance under the new SEC guidelines.

It's been made clear that the net performance requirement applies not only to performance of an entire composite or portfolio, but also to that of a subset of investments or a single investment. If the gross performance of a single investment is shown, net performance also needs to be presented. When presenting extracted performance, firms should apply a model fee to calculate the net return, include appropriate disclosures, and be able to support why they’re presenting this information.

This gets a little trickier when considering attribution, and many firms are still figuring out how to navigate this grey area. The SEC will likely want to see attribution net-of-fees in some cases but not others. For now, it seems providing clear documentation for what’s shown and why is key. According to the panel, things like average weight and Sharpe ratio seem less likely to be considered performance, while contribution to return seems more likely to be considered performance. Yield in particular was discussed in detail, with the takeaway being that if yield is presented in a way that it is synonymous with a return and what investors can expect to take home, this may be subject to the net performance requirement.

Some other takeaways from this panel discussion on attribution are that metrics derived from performance and those that are relative to a benchmark are less likely to be considered performance in the eyes of the SEC. Firms should be able to support their decision of what they consider performance and be aware of the context in which attribution is being presented.

This panel also touched on key deficiencies from recent SEC exams, as well as what to expect for the next round of exams. While Phase I focused on more evaluating whether firms were addressing the new rule, Phase II is expected to include a deep dive across 175-200 firms. This will also include 20-25 exams involving recalculation of performance, as well as a focus on predecessor performance and testimonials/endorsements.

Some of the deficiencies the panel touched on from Phase I were material misstatements in advertisements, manipulation of performance, omitting poor performance, and failure to present net-of-fee performance. Another deficiency noted was the lack of policies and procedures around presenting hypothetical performance. The key to presenting hypothetical performance is that recipients must be able to fully understand what is being shown, and that this performance is not being distributed to a retail audience. You also need to have the ability to recreate any hypothetical performance presented, as this has the potential to be tested by the SEC.

To get ready for the next phase of SEC exams, firms should make sure their policies and procedures are designed to prevent violations of the marketing rule and that their marketing materials comply. We recommend extending this review to your website to ensure historical information published prior to adoption of the new rule is also in compliance. One suggestion from the panel was to leverage other firms in the industry to see what types of disclosures are being used. Many large firms are putting a lot of time and resources into navigating the marketing rule, so leveraging these firms as best practice is encouraged.

WiPM Group

Officially launched in late 2022, the Women in Performance Measurement (WiPM) Group was developed as a resource for women in the investment performance industry to connect with, learn from, and uplift one another. With initial members of the group spread across multiple regions and countries, the first in-person meeting had an impressive turnout of over 50 attendees.

The meeting featured Lisa Kaplowitz as its keynote speaker. Kaplowitz is a professor at Rutgers Business School and is the Executive Director at Rutgers Center for Women in Business. Her background includes everything from taking part in the landmark Title IX case to multiple CFO positions. Throughout her career, Kaplowitz has remained a champion of women and challenging the status quo.

Kaplowitz shared statistics supporting that the majority of women in C-suite positions competed in athletics, with nearly half of those executives being previous college-level athletes. This connection may not be all that surprising when you consider the life lessons around discipline, resiliency, and teamwork that are taught through athletics and the valuable leadership skills that are developed through those experiences. She also offered some insightful information on maladaptations women have to endure to survive in the workforce today and offered suggestions for addressing them. This topic really seemed to resonate with the group.

Another topic discussed was how to make the workplace “work” for women, which led to some insightful conversations during the WiPM panel discussion that touched on work life balance and the unique challenges women face in the workforce, particularly the performance measurement industry.

The group is working out details of a mentorship program that will help facilitate relationships between women across the industry and allow them to share the knowledge and experience gained throughout their careers. This program is expected to launch in the fall of 2023 and is open to all women within the WiPM group.

Anyone interested in the WiPM Group is encouraged to contact us to get connected.

Conclusion

This year’s PMAR speakers offered a lot of great insights on topics related to investment performance measurement and challenges facing the industry.

We enjoyed connecting with other performance measurement professionals in-person and are looking forward to attending future PMAR and WiPM events.

If you have any questions about the 2023 PMAR Conference topics or GIPS compliance and performance measurement in general, please contact us.

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Key Takeaways from the 29th Annual GIPS® Standards Conference in Phoenix

The 29th Annual Global Investment Performance Standards (GIPS®) Conference was held November 11–12, 2025, at the Sheraton Grand at Wild Horse Pass in Phoenix, Arizona—a beautiful desert resort and an ideal setting for two days of discussions on performance reporting, regulatory expectations, and practical implementation challenges. With no updates released to the GIPS standards this year, much of the content focused on application, interpretation, and the broader reporting and regulatory environment that surrounds the standards.

One of the few topics directly tied to GIPS compliance with a near-term impact relates to OCIO portfolios. Beginning with performance presentations that include periods through December 31, 2025, GIPS compliant firms with OCIO composites must present performance following a newly prescribed, standardized format. We published a high-level overview of these requirements previously.

The conference also covered related topics such as the SEC Marketing Rule, private fund reporting expectations, SEC exam trends, ethical challenges, and methodology consistency. Below are the themes and observations most relevant for firms today.

Are Changes Coming to the GIPS Standards in 2030?

Speakers emphasized that while no new GIPS standards updates were introduced this year, expectations for consistent, well-documented implementation continue to rise. Many attendee questions highlighted that challenges often stem more from inconsistent application or interpretation than from unclear requirements.

Several audience members also asked whether a “GIPS 2030” rewrite might be coming, similar to the major updates in 2010 and 2020. The CFA Institute and GIPS Technical Committee noted that:

    ·   No new version of the standards is currently in development,

     ·   A long-term review cycle is expected in the coming years, and

     ·   A future update is possible later this decade as the committee evaluates whether changes are warranted.

For now, the standards remain stable—giving firms a window to refine methodologies, tighten policies, and align practices across teams.

Performance Methodology Under the SEC Marketing Rule

The Marketing Rule featured prominently again this year, and presenters emphasized a familiar theme: firms must apply performance methodologies consistently when private fund results appear in advertising materials.

Importantly, these expectations do not come from prescriptive formulas within the rule. They stem from:

1.     The “fair and balanced” requirement,

2.     The Adopting Release, and

3.     SEC exam findings that view inconsistent methodology as potentially misleading.

Common issues raised included: presenting investment-level gross IRR alongside fund-level net IRR without explanation, treating subscription line financing differently in gross vs. net IRR, and inconsistently switching methodology across decks, funds, or periods.

To help firms void these pitfalls, speakers highlighted several expectations:

     ·   Clearly identify whether IRR is calculated at the investment level or fund level.

     ·   Use the same level of calculation for both gross and net IRR unless a clear, disclosed rationale exists.

     ·   Apply subscription line impacts consistently across both gross and net.

     ·   Label fund-level gross IRR clearly, if used(including gross returns is optional).

     ·   Ensure net IRR reflects all fees, expenses, and carried interest.

     ·   Disclose any intentional methodological differences clearly and prominently.

     ·   Document methodology choices in policies and apply them consistently across funds.

This remains one of the most frequently cited issues in SEC exam findings for private fund advisers. In short: the SEC does not mandate a specific methodology, but it does expect consistent, well-supported approaches that avoid misleading impressions.

Evolving Expectations in Private Fund Client Reporting

Although no new regulatory requirements were announced, presenters made it clear that limited partners expect more transparency than ever before. The session included an overview of the updated ILPA reporting template along with additional information related to its implementation. Themes included:

     ·   Clearer disclosure of fees and expenses,

     ·   Standardized IRR and MOIC reporting,

     ·   More detail around subscription line usage,

     ·   Attribution and dispersion that are easy to interpret, and

     ·   Alignment with ILPA reporting practices.

These are not formal requirements, but it’s clear the industry is moving toward more standardized and transparent reporting.

Practical Insights from SEC Exams—Including How Firms Should Approach Deficiency Letters

A recurring theme across the SEC exam sessions was the need for stronger alignment between what firms say in their policies and what they do in practice. Trends included:

     ·   More detailed reviews of fee and expense calculations, especially for private funds,

     ·   Larger sample requests for Marketing Rule materials,

     ·   Increased emphasis on substantiation of all claims, and

     ·   Close comparison of written procedures to actual workflows.

A particularly helpful part of the discussion focused on how firms should approach responding to SEC deficiency letters—something many advisers encounter at some point.

Christopher Mulligan, Partner at Weil, Gotshal & Manges LLP, offered a framework that resonated with many attendees. He explained that while the deficiency letter is addressed to the firm by the exam staff, the exam staff is not the primary audience when drafting the response.

The correct priority order is:

1. The SEC Enforcement Division

Enforcement should be able to read your response and quickly understand that: you fully grasp the issue, you have corrected or are correcting it, and nothing in the finding merits escalation.

Your first objective is to eliminate any concern that the issue rises to an enforcement matter.

2. Prospective Clients

Many allocators now request historical deficiency letters and responses during due diligence. The way the response is written—its tone, clarity, and thoroughness—can meaningfully influence how a firm is perceived.

A well-written response shows strong controls and a culture that takes compliance seriously.

3. The SEC Exam Staff

Although examiners issued the letter, they are the third audience. Their primary interest is acknowledgment and a clear explanation of the remediation steps.

Mulligan emphasized that firms often default to writing the response as if exam staff were the only audience. Reframing the response to keep the first two audiences in mind—enforcement and prospective clients—helps ensure the tone, clarity, and level of detail are appropriate and reduces both regulatory and reputational risk.

Final Thoughts

With no changes to the GIPS standards introduced this year, the 2025 conference in Phoenix served as a reminder that the real challenges involve consistency, documentation, and communication. OCIO providers in particular should be preparing for the upcoming effective date, and private fund managers continue to face rising expectations around transparent, well-supported performance reporting.

Across all sessions, a common theme emerged: clear methodology and strong internal processes are becoming just as important as the performance results themselves.

This is exactly where Longs Peak focuses its work. Our team specializes in helping firms document and implement practical, well-controlled investment performance frameworks—from IRR methodologies and composite construction to Marketing Rule compliance, fee and expense controls, and preparing for GIPS standards verification. We take the technical complexity and turn it into clear, operational processes that withstand both client due diligence and regulatory scrutiny.

If you’d like to discuss how we can help strengthen your performance reporting or compliance program, we’d be happy to talk. Contact us.

From Compliance to Growth: How the GIPS® Standards Help Investment Firms Unlock New Opportunities

For many investment managers, the first barrier to growth isn’t performance—it’s proof.
When platforms, consultants, and institutional investors evaluate new strategies, they’re not just asking how well you perform; they’re asking how you measure and present those results.

That’s where the GIPS® standards come in.

More and more investment platforms and allocators now require firms to comply with the GIPS standards before they’ll even review a strategy. For firms seeking to expand their reach—whether through model delivery, SMAs, or institutional channels—GIPS compliance has become a passport to opportunity.

The Opportunity Behind Compliance

Becoming compliant with the GIPS standards is about more than checking a box. It’s about building credibility and transparency in a way that resonates with today’s due diligence standards.

When a firm claims compliance with the GIPS standards, it demonstrates that its performance is calculated and presented according to globally recognized ethical principles—ensuring full disclosure and fair representation. This helps level the playing field for managers of all sizes, giving them a chance to compete where it matters most: on results and consistency.

In short, GIPS compliance doesn’t just make your reporting more accurate—it makes your firm more credible and discoverable.

Turning Complexity Into Clarity

While the benefits are clear, the process can feel overwhelming. Between defining the firm, creating composites, documenting policies and procedures, and maintaining data accuracy—many teams struggle to find the time or expertise to get it right.

That’s where Longs Peak comes in.

We specialize in simplifying the process. Our team helps firms navigate every step—from initial readiness and composite construction to quarterly maintenance and ongoing training—so that compliance becomes a seamless part of operations rather than a burden on them.

As one of our clients put it, “Longs Peak helps us navigate GIPS compliance with ease. They spare us from the time and effort needed to interpret what the requirements mean and let us focus on implementation.”

Real Firms, Real Impact

We’ve seen firsthand how GIPS compliance can transform firms’ growth trajectories.

Take Genter Capital Management, for example. As David Klatt, CFA and his team prepared to expand into model delivery platforms, managing composites in accordance with the GIPS standards became increasingly complex. With Longs Peak’s customized composite maintenance system in place, Genter gained the confidence and operational efficiency they needed to access new platforms and relationships—many of which require firms to be GIPS compliant as a baseline.

Or consider Integris Wealth Management. After years of wanting to formalize their composite reporting, they finally made it happen with our support. As Jenna Reynolds from Integris shared:

“When I joined Integris over seven years ago, we knew we wanted to build out our composite reporting, but the complexity of the process felt overwhelming. Since partnering with Longs Peak in 2022, they’ve been instrumental in driving the project to completion. Our ongoing collaboration continues to be both productive and enjoyable.”

These are just two examples of what happens when compliance meets clarity—firms gain time back, confidence grows, and new business doors open.

Why It Matters—Compliance as a Strategic Advantage

At Longs Peak, we believe compliance with the GIPS standards isn’t a cost—it’s an investment.

By aligning your firm’s performance reporting with the GIPS standards, you gain:

  • Access to platforms and institutions that require GIPS compliant firms.
  • Credibility and trust in an increasingly competitive landscape.
  • Operational efficiency through consistent data and documented processes.
  • Scalability to support multiple strategies and distribution channels.

Simply put: compliance fuels confidence—and confidence drives growth.

Simplifying the Complex

At Longs Peak, we’ve helped over 250 firms and asset owners transform how they calculate, present, and communicate their investment performance. Our goal is simple: make compliance with the GIPS standards practical, transparent, and aligned with your firm’s growth goals.

Because when compliance works efficiently, it doesn’t slow your business down—it helps it reach further.

Ready to turn compliance into a growth advantage?

Let’s talk about how we can help your firm simplify the complex.

📧 hello@longspeakadvisory.com
🌐 www.longspeakadvisory.com

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!