Around the Peak.

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.
Recommended
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.
Every Spring, the performance measurement community gathers for PMAR: The Performance Measurement, Attribution & Risk Conference, hosted by TSG. This year marked the twenty-fourth annual, and I left thinking about it differently than I have in years past.
Most years, the themes evolve gradually. This year, I felt like the ground was moving.
The theme nobody put on the agenda but ran underneath nearly every session was the pace of change. Specifically, what artificial intelligence is about to do to our work. And while I came away energized, I also came away with a healthy dose of " we (as in everyone) are not ready for how fast this is coming."
Here's what stayed with me.
AI Was the Undercurrent of the Whole Event
The session titled "AI, Anxiety, and Opportunity: What Performance Professionals Need to Know" was, predictably, one of the most sought-after sessions of the conference. The panel, which included practitioners from across the industry, did a nice job naming both sides of the coin: the anxiety of not knowing what your job looks like in five years, and the opportunity sitting right in front of us if we lean in.
Here's my honest read of the room, though. The mood was optimistic. Maybe a little too optimistic. There was a comfortable assumption that AI will mostly handle the tedious parts and leave the interesting work to us. Or that AI won’t take your job, someone that knows AI will. I'm not sure it'll be that tidy.
From what we're already seeing in our own work and across the firms we serve, the capabilities are advancing faster than most people can comprehend. The days where “our industry is just slower to adapt” are gone. Just last week, anthropic released Fable 5 and before it was shut down (temporarily?), we played around with it a little and its capabilities are dumbfounding. I don't think it will be long before these conferences look drastically different. Different sessions, different vendors, maybe a different sense of what the job even is. That's not a doom prediction. It's just a reason to pay closer attention than feels comfortable.
Separating Skill From Luck Just Got Harder and More Important
One of my favorite sessions was Michael Ervolini's "You Can't Find Skill in Returns: Distinguishing Performance From the Decisions That Generate Them." It's a deceptively simple premise: returns tell you what happened, not whether the manager was actually good. A great number can come from a great decision, or from luck. A bad number can hide genuine skill.
What I appreciate about PMAR is that the community keeps bringing fresh perspectives to this old, hard problem: how do we actually evaluate skill versus luck? It's a question that never fully resolves, and every year someone pushes the thinking forward.
It struck me that this question gets more important in an AI world, not less. As machines take over more of the calculation and even some of the decision-making, our value shifts toward judgment – knowing which decisions deserved credit, which results were noise, and what a number actually means in context. That's the kind of discernment a model can assist with but can't own. For more from Mr. Ervolini, here's a link to his latest book Skill vs. Luck.
The GIPS Challenges That Keep Coming Back
I'm biased here, but the "Common GIPS Challenges and How to Avoid Them" session was a highlight for us, in part because our own Matthew Deatherage, CFA, CIPM, was on the panel alongside peers from TSG, MassPRIM, and Strategic Investment Group.
What I always find striking about this topic is how consistent the challenges are. Firms pursuing compliance with the Global Investment Performance Standards (GIPS®)* tend to stumble on the same handful of issues year after year, and almost all of them are avoidable with the right foundation in place. That's a big part of why we do what we do at Longs Peak: helping firms get ahead of those pitfalls instead of discovering them during verification or, worse, during a regulatory exam.
Matt is a familiar face on these panels, and it's great to have our perspective in the mix. But the takeaway that stuck with me tied right back to the AI thread running through the whole conference.
Across several different panels, presenters talked about feeding the GIPS standards into their own AI models to churn out GIPS reports. And here's the thing, anyone can do that. You can drop the standards into a model in minutes. What a model can't do is provide critical judgment about how a principles-based framework should be applied to your specific facts and circumstances and whether those GIPS reports and statistics were calculated correctly. The GIPS standards aren't a checklist; they're a set of principles that require interpretation, and interpretation is exactly where experience earns its keep.
I'm not saying don't use AI to help build a framework. Use it. But like any model, if you don't really know what you're asking it to do, the output won't save you. Simply asking a model to "make my firm GIPS compliant" isn't going to make it so. At least not yet!
And there's one problem every performance professional already knows AI hasn't solved: data. As they say, garbage in, garbage out. Meaningful performance lives and dies on clean, well-organized data, and no software tool or AI model fixes messy inputs alone. At Longs Peak, we have spent the last 10 years working with clients to improve data quality through data integrity testing. For us, these AI models have only expanded what’s possible. We know one thing for sure: setting these tools up with the proper context (i.e., knowing what to look for) and then evaluating that context on an ongoing basis may turn out to be the most crucial piece of it all.
CFA Institute Is Listening on the CIPM
A session I didn't expect to find as interesting as I did was "CIPM Through the Practitioner Lens," facilitated by Rob Langrick of CFA Institute. Rather than simply presenting at the room, CFA Institute came to listen and gather candid feedback on the CIPM designation: where it's delivering value, where it's falling short, and how it should evolve to stay relevant to the work we actually do day to day.
The audience didn't hold back, and there were some genuinely thoughtful suggestions including how the code of ethics will evolve in this new AI era, some recommendations on reformatting the exam to break it into smaller chunks (going into greater detail on each) as well as adding a CIPM group within the CFA societies to encourage further connection. It was refreshing to see CFA Institute putting real energy behind a credential that so many of us have invested in and want to see grow in value. Given the pace of change in our field, willingness to adapt feels necessary. For anyone interested in contributing ideas to the CIPM, you can use this link to provide feedback.
A Quick Word on the Trivia
I'd be remiss not to mention that Performance Trivia got a much-needed upgrade this year. In past years, only a handful of contestants got to play while the rest of us watched (though in fairness, not all of us were clamoring for the spotlight). The new format this time allowed everyone to participate (without taking center stage), and it was a lot more fun for it. A small change, but it captured something I value about this community: it's competitive, but it's also genuinely collegial and prides itself on memorizing quirky names and vintage formulas.
Before PMAR Even Started: Women in Performance Measurement
For me, the week actually started the day before the conference, at the Women in Performance Measurement (WiPM) gathering. An event created just for the women in our industry. It's one of my favorite parts of this trip every year, and not only because the conversation is good. There's something energizing about being in a room full of women who do this work, comparing notes and reconnecting.
Fittingly, AI came up here too, though in a much more hands-on way than it would on the main stage. Practitioners shared real use cases, both personal and professional: the small ways AI is already saving them time day to day, and the bigger experiments they're running at their firms. It was practical, curious, and refreshingly free of hype.
We were also lucky to have a guest speaker, Lidia Arshavsky, who spoke on executive presence. She broke down how executive presence actually gets evaluated inside organizations (the signals people pick up on, often without realizing it) and offered practical recommendations for strengthening your own. It was the kind of talk that's useful no matter where you are in your career.
It was a great way to kick off PMAR, and an even better way to reconnect with women I only get to see a few times a year. Sometimes the most valuable part of a conference happens in these opportunities to network and reconnect within our niche performance community. A big thank you to TSG who donated the space for this event to take place and have done so for many years.
What AI Can't Take From Us
The conference's forward-looking sessions, including "Innovative Ways to Present Performance: Dashboards & Analytics," got me thinking. The tools are evolving so quickly and so much of the analysis, presentation, and reporting can now be automated. I am left wondering how long the traditional use of software in our space will last in its current form.
When the capabilities advancing fastest don’t always come from the established vendors, who benefits? My hope is that everyone does. That these tools level a playing field that used to tilt heavily toward the largest institutions, give smaller firms the ability to deliver high-caliber analytics previously out of reach, and push the whole field toward better solutions. That makes for a more competitive space and ultimately a clearer picture for investors to evaluate their options.
That's the optimistic case, and I believe it. But it only holds if we stay clear-eyed about where our own value comes from and that's the note I want to leave you on. The pace of change is a reason to focus, not to panic. The things that make us valuable are the things AI can't take: consciousness, judgment, and the human-in-the-loop accountability that clients ultimately trust. Machines will calculate faster and present prettier. They won't sit across the table from a client and take responsibility for what a number actually means.
So, by all means, get curious about the tools (Claude seemed to be most people’s favorite – mine as well). Experiment. Don't be the individual or firm that gets left behind. But anchor yourself in the part of this work that's irreplaceably human, because that's the part that was always the point.
See you at PMAR 2027. I suspect it'll look a little different.
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GIPS® is a registered trademark owned by CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein.
Mission-driven institutions are entrusted with something larger than capital. They are entrusted with purpose.
Endowments, foundations, and long-term investment pools exist to support education, healthcare, research, environmental initiatives, religious or cultural programs, community development, and countless other causes—often for generations.
That long-term horizon changes how investment performance should be reported. Because when an institution thinks in decades instead of quarters, investment performance is not just about what happened recently, itis about whether the portfolio is structured to sustain spending, preserve purchasing power, and remain aligned with its mission through full market cycles.
Many institutions rely entirely on their investment managers to calculate and present investment performance. That’s common, but it’s not always sufficient.
Performance Oversight Is Not the Same as Performance Results
Investment managers are responsible for generating returns. Boards and oversight committees are responsible for evaluating those results.
Those responsibilities are distinct.
Oversight is a fiduciary duty. It is not passive, and it cannot rely solely on the information created by the party being evaluated. Effective oversight requires independence, consistency, and clarity.
When the same party both manages assets and determines how performance is calculated and presented, the lines between management and oversight can blur—even when intentions are sound and calculations are technically accurate.
In some situations, reporting may not be:
- Consistent across managers
- Based on uniform calculation methodologies
- Presented in a format designed for governance review
- Structured to facilitate long-term policy evaluation
Consider a board reviewing results from three different managers. Each reports strong performance, but one calculates returns net-of-fees, another presents gross results, and a third uses slightly different valuation timing.
At first glance, the numbers appear comparable. In reality, they may not be measuring the same thing.
Some larger institutions maintain internal performance teams or engage independent performance professionals to standardize reporting, organize data across managers, and present results in accordance with established best practices—often aligning reporting with their Investment Policy Statement and/or recognized frameworks such as the Global Investment Performance Standards (GIPS® standards).
But many of these organizations operate lean. They may not have dedicated performance measurement expertise or the infrastructure required to consolidate, normalize, and present results in a governance-ready format.
In those cases, boards are often reviewing manager-produced materials that were designed primarily for client communication—not institutional oversight. Performance reporting for these institutions should be designed to serve the governing body—not simply to showcase results.
Why This Matters for Mission-Based Institutions
Boards of endowments and foundations are often composed of dedicated volunteers, philanthropists, community leaders, and subject-matter experts. They bring vision, experience, and commitment to the institution’s mission—but not always a deep understanding of investment management and reporting.
That makes investment performance clarity essential. When reporting is unclear, oversight weakens—not because trustees lack commitment, but because the information is not presented in a way that supports meaningful evaluation.
When reporting is structured and tied directly to policy benchmarks, risk parameters, and spending objectives, trustees know what questions to ask. Conversations remain focused on long-term sustainability and mission impact.
A Practical Framework for Strong Performance Reporting
Boards of mission-driven institutions are often operating at the governance-level and should evaluate their reporting structure against four questions:
1. Is performance calculated independently?
Independent calculation or oversight reduces potential conflicts and strengthens fiduciary governance. In institutional investing, separating portfolio management from performance oversight is widely viewed as a best practice.
2. Is the methodology consistent across managers?
Multi-manager portfolios require uniform return calculation, fee treatment, and valuation policies to ensure comparability. Without consistency, “relative performance” becomes difficult to interpret.
One practical way institutions address this challenge is by complying with and requiring their managers to comply with the GIPS® standards.
The GIPS standards are a globally recognized framework administered by CFA Institute designed to promote fair representation and full disclosure in the calculation and presentation of investment performance.
Endowments and foundations that adopt the GIPS standards for their own performance calculations—and require the same of the managers they hire—send a powerful message to their boards and stakeholders that the institution is committed to transparency in how results are calculated and presented.
3. Is reporting aligned with policy benchmarks?
Boards should see performance relative to long-term policy objectives, not just absolute returns. And this information should be shown at the level at which it is managed. Simply reporting that “the portfolio returned 8%” does not answer the real governance question.
A portfolio can have a positive year and still fail to meet its strategic role within the overall allocation.
For example:
- Did the equity allocation meet its return objective relative to its benchmark?
- Did the diversifying strategies provide the downside protection they were intended to deliver?
- Did fixed income serve its role as a stabilizer?
- Did alternative investments justify their complexity and liquidity constraints?
Even if the overall portfolio met its expected return, boards should understand how it got there. Reviewing performance by allocation allows boards to evaluate whether each segment is fulfilling its mandate, not just whether the total return looks acceptable.
When reported this way, it becomes easier to see where the portfolio is meeting expectations and where it may be falling short.
4. Is communication designed for governance?
Once performance is aligned to policy benchmarks, reporting should help trustees interpret what the results mean without requiring them to operate at the manager or security-selection level.
Reports should help answer key questions:
· Are we meeting long-term objectives?
· How are managers performing relative to their mandates?
· Is risk aligned with the investment policy?
· Are we preserving capital appropriately given our spending needs?
· Did managers follow investment guidelines that align with our institution’s mission?
If any of these areas underperform, governance-level reporting should prompt clear, high-level discussion: Why did this occur? Was the result consistent with expectations? What steps, if any, are being considered to address issues going forward? If shortfalls persist, boards may need to evaluate whether the strategy or manager remains appropriate.
This kind of oversight strengthens outcomes by reinforcing accountability. Performance reporting should be communicated in plain language and simplify complex data into clear actionable insight. When this occurs, it enables boards to move from procedural review toward informed, effective governance.
From Calculation to Communication
Accurate returns are the starting point. Clear communicationis the outcome.
When performance calculation, oversight, and presentation are thoughtfully structured, board discussions become more strategic and less reactive. Boards gain confidence in their oversight, managers operate within clearer expectations, and the institution stays focused on its purpose.
A Closing Thought
Mission-driven institutions think in decades, not quarters. Their performance reporting should reflect that same discipline. Investment oversight is not just about generating returns, it is about ensuring those returns are measured, understood, and aligned with the institution’s long-term purpose.
Clear reporting strengthens governance.
Strong governance protects sustainability.
And sustainability protects the mission.
If you’ve been around the Global Investment Performance Standards (GIPS®) long enough, you know that governance is one of those topics everyone agrees is important, but far fewer firms can clearly explain what good governance with the GIPS standards actually looks like day to day.
Most firms don’t fail at GIPS compliance because they misunderstand a technical requirement. They struggle because ownership is unclear, decisions are informal, or key knowledge lives in one person’s head. When that person leaves (or when the firm grows) things start to break.
So, let’s simplify this.
Below is a practical, real-world view of what good governance looks like when complying with the GIPS standards—not in theory, not in a policy document that no one reads, but in how well-run firms actually operate.
Start with the Right Mindset: Governance Is About Sustainability
At its core, GIPS compliance exists to answer one question:
Can this firm consistently calculate, maintain, and present performance fairly and accurately—regardless of growth, staff changes, or market stress?
The GIPS standards are built on the principles of fair representation and full disclosure, but governance is what turns those principles into repeatable behavior. Good governance doesn’t mean more paperwork or compliance headaches. It means clear accountability, documented decisions, and controls that actually get used.
1. Clear Ownership (It’s Rarely Just One Person)
One of the most common governance risks we see is a “GIPS compliance department of one” where critical knowledge, decisions, and processes are concentrated with a single individual. While this can work in the short term, it creates challenges around continuity, oversight, and scalability as the firm grows or changes.
Good governance starts by clearly defining:
- Who owns GIPS compliance overall
- Who performs monthly/quarterly/annual tasks
- Who reviews and approves key inputs/outputs
- Who resolves judgment calls
- Who ensures it also complies with other relevant regulations
In practice, this often looks like:
- A GIPS compliance committee or designated governance group
- Representation from performance, compliance, operations, and senior management
- Defined escalation paths for gray areas (e.g., discretion, composite changes, error corrections)
When a firm isn’t large enough to support a formal committee, outsourcing to a GIPS compliance consultant or a provider of managed services can be an effective alternative. These individuals can help you design policies, create procedures, and essentially manage governance for you.
But even if you are big enough, having an independent third party on your GIPS compliance committee can provide an objective, well-informed perspective formed by experience across many firms and a deep understanding of what works well in practice.
2. Policies and Procedures That Reflect Reality
Every GIPS compliant firm has GIPS standards policies and procedures (GIPS standards P&P). Well-governed firms actually use them.
Strong GIPS compliance governance means your GIPS standards P&P:
- Include procedures your firm actually follows instead of only stating policies
- Reflect how performance is really calculated
- Clearly document firm-specific elections and judgments
- Are updated when the business changes (for new products, systems, asset classes)
Think of your GIPS standards P&P as the firm’s operating manual for performance, not a static compliance artifact. If someone new joined your performance team tomorrow, they should be able to follow your policies and procedures to calculate performance and arrive at the same results. If not, governance needs work.
3. Formalized Review and Oversight
Good governance includes independent review, even if it’s internal.
In practice, this often means:
- Secondary review of composite membership decisions
- Review of significant cash flow thresholds and discretion determinations
- Approval of new composites and composite definition changes
- Oversight of error identification and correction
This is where governance protects firms from subtle but costly mistakes, especially those that show up during verification and increase complexity and scope of these engagements. In an ideal situation, these internal reviews should catch issues before they become problems.
As a provider of managed services, Longs Peak helps firms identify performance outliers, accounts that are breaking composite rules, and other data anomalies. This review significantly reduces the risk of erroneous data ending up in your performance and later caught in verification. If you are not able to do this internally, we strongly recommend outsourcing this effort.
4. Governance Extends to Marketing and Distribution
One area that has been increasingly important is the intersection of GIPS compliance, the SEC marketing rule, and how you manage the distribution of marketing materials.
Well-governed firms:
- Control who can distribute GIPS Reports and how they are distributed
- Ensure Marketing understands what is and is not an advertisement that meets the requirements of the GIPS standards
- Coordinate GIPS compliance requirements with broader regulatory rules, including the SEC marketing rule
- Have a clear process for tracking distribution
This alignment helps firms avoid inconsistencies between factsheets, pitchbooks, and GIPS Reports—one of the fastest ways to lose credibility with prospects and regulators.
Some clients prefer not to mention GIPS compliance at all in their marketing (i.e., on their factsheets and pitchbooks) until a client is clearly interested in one of their strategies. Once they meet the definition of a prospect (as outlined in your GIPS standards P&P), it triggers the requirement to send a GIPS Report and they find this smaller list of prospects easier to maintain. For others, having everything in one document including required GIPS compliance information and disclosures is easier to manage than separate documents.
There is no “right” way to manage this, but in either case, having a clear process for tracking and reporting performance errors is key.
5. Documentation of Decisions (Not Just Results)
Here’s a subtle but critical point: Good governance for your GIPS compliance program documents decisions, not just outcomes.
Why was that composite redefined?
Why was this benchmark changed?
Why was this model fee selected?
Strong governance creates an audit trail that:
- Supports sound reasoning (which aides in the verification process or even regulatory exams later on)
- Reduces key person risk
- Makes future reviews faster and less stressful
This is especially valuable when firms grow, merge, or experience turnover. Clear documentation allows others to step in seamlessly and continue critical functions without disruption. More importantly, it enables independent parties, such as a regulator or your verifier, to understand, assess, and validate how you are calculating and presenting performance that may not be immediately intuitive.
6. Governance Is Ongoing, Not a One-Time Project
The best-governed firms don’t “set and forget” their GIPS compliance program. They revisit governance when:
- New strategies launch
- Systems or custodians change
- Regulations evolve
- The firm’s structure changes
In other words, governance evolves with the business—because performance reporting doesn’t exist in a vacuum.
Even for firms that are not regularly launching new strategies, changing systems or structure, an annual review of your GIPS compliance program and governance framework is critical. This review helps confirm that practices have remained consistent, while also providing an opportunity to reflect on whether you are satisfied with your verifier, assess whether new regulations require updates, and reconsider how composites are managed or described.
The best time to do this is at year-end so that if you decide something should be changed, you can do that proactively for the upcoming year, rather than having to fix it retroactively.
What Good GIPS Compliance Governance Really Buys You
When GIPS compliance governance is working well, firms experience:
- A structured, intentional process for validation of your performance results
- A framework that supports consistency and transparency over time
- Fewer surprises or last-minute scrambles during verification or regulatory review
- Greater confidence from regulators and verifiers that you are following established policies and procedures
- Lower operational and reputational risk
Most importantly, it creates trust internally and externally. Good GIPS compliance governance isn’t about being perfect. It’s about being intentional.
Clear ownership. Thoughtful documentation. Real oversight. Those are the firms that don’t just claim compliance, they live it.
Why “Net” Is Not a One-Size-Fits-All Answer
If you’ve worked in the investment industry, you’ve probably heard some version of this question:
“Should we show net or gross performance—or both?”
On the surface, the answer seems straight forward. The rules tell us what’s required. Compliance boxes get checked. End of story.
But in practice, presenting net and gross performance is rarely that simple.
How you calculate it, how you present it, and how you disclose it can materially change how investors interpret your results. This article goes beyond the rulebook to explore thepractical considerations firms face when deciding how to present net and gross returns in a manner that is clear, helpful, and in compliance with requirements.
Let’s Start with the Basics (Briefly)
At a high level, for separate account strategies:
- Gross performance reflects returns before investment management fees
- Net performance reflects returns after investment management fees have been deducted
Both gross and net performance are typically net of transaction costs, but gross of administrative fees and expenses. When dealing with pooled funds, net performance is also reduced by administrative fees and expenses, but here we are focused on separate account strategies, typically marketed as composite performance.
Simple enough. But that definition alone doesn’t tell the full story—and it’s where many misunderstandings begin.
Why Net Performance Is the Investor’s Reality
From an investor’s perspective, net performance is what actually matters. It represents the return they keep after paying the manager for active management.
That’s why modern regulations and best practices increasingly emphasize net returns. Investors don’t experience gross returns. They experience net outcomes.
And let’s be honest: if an investor chooses an active manager instead of a low-cost index fund or ETF tracking the same benchmark, the expectation is that the active approach should deliver something extra—after fees. Otherwise, it becomes difficult to justify paying for that active management.
Why Gross Performance Still Has a Role
If net returns are what investors actually receive, why do firms still talk about gross performance at all?
Because gross performance tells a different, but complementary, story: what the strategy is capable of before fees, and what investors are paying for that capability.
The gap between gross and net returns represents the cost of active management. Put differently, it answers a question investors are implicitly asking:
How much return am I giving up in exchange for this manager’s expertise?
Viewed this way, gross returns help investors assess:
- Whether the strategy is adding value before fees
- How much of the performance is driven by skill: security selection, asset allocation or portfolio construction
- Whether fees are the primary drag—or whether the strategy itself is struggling
When gross and net returns are shown together, they create transparency around both skill and cost. When shown without context, they can easily obscure the economic tradeoff.
Gross-of-fee returns are also most important when marketing to institutional investors that have the power to negotiate the fee they will pay and know that they will likely pay a fee lower than most of your clients have paid in the past. Their detailed analysis can more accurately be done starting with your gross-of-fee returns and adjusting for the fee they expect to negotiate rather than using net-of-fee returns that have been charged historically.
The Real-World Gray Areas Firms Struggle With
How to Present Gross Returns
Gross returns are pretty straightforward. They are typically calculated before investment management or advisory fees and usually include transaction costs such as commissions and spreads.
For firms that comply with the GIPS® Standards, things can get more nuanced—particularly for bundled fee arrangements. In those cases, firms must make reasonable allocations to separate transaction costs from the bundled fee. But, if that separation cannot be done reliably, gross returns must be shown after removing the entire bundled fee. [1]
Once you move from gross to net returns, however, the conversation becomes less straightforward. We’ve had managers question, “why show net performance at all?” This is especially the case when fees vary across clients or historical fees no longer reflect what an investor would pay today. Others complain that the “benchmark isn’t net-of-fees,” making net-of-fee comparisons inherently imperfect. These concerns highlight why presenting net returns isn’t just a mechanical exercise. In the sections that follow, we’ll unpack these challenges and walk through how to present net-of-fee performance in a way that remains meaningful, transparent, and fit for its intended audience.
How to Present Net Returns
This is where judgment and documentation matters most.
Not all “net” returns are created equal. Even under the SEC Marketing Rule, there is no single mandated definition of net performance—only a requirement that net performance be presented. Under the GIPS Standards, net-of-fee returns must be reduced by investment management fees.
In practice, firms may deduct:
- Advisory fees (asset-based investment management fees)
- Performance-based fees
- Custody fees
- Transaction costs
Two net-return series can look comparable on the surface while reflecting very different assumptions underneath. This lack of transparency is one of the main reasons institutional investors often require managers to be GIPS compliant—it simplifies comparison by requiring consistency in the assumptions used and how they are presented or additional disclosure when more fees are included in the calculation than what is required.
And context matters. A higher fee may be perfectly reasonable if it reflects broader services such as tax or financial planning, holistic portfolio construction, or access to specialized strategies. The problem isn’t the fee itself, it’s failing to use a fee scenario that is relevant to the user of the report.
Deciding Between Actual vs Model Fees
The next hurdle is deciding whether to use actual fees or a model fee when calculating net returns. Historically, firms most often relied on actual fees, viewing them as the best representation of what clients actually experienced. But that approach raises an important question: are those historical fees still relevant to what an investor would pay today? If the answer is no, a model fee may provide a more representative picture of current expected outcomes. Under the SEC marketing rule, there are cases where firms are required to use a model fee when the anticipated fee is higher than actual fees charged.
This consideration becomes even more important for strategies or composites that include accounts paying little or no fee at all. While the GIPS Standards and the SEC Marketing Rule are not perfectly aligned on this topic, they agree in principle—net performance should be meaningful, not misleading, and should reflect what an actual fee-paying investor should reasonably expect to pay. Thus, many firms opt to present model fee performance to avoid violating the marketing rule’s general prohibitions. [2]
Additional SEC guidance published on Jan 15, 2026 on the Use of Model Fees reinforced that the decision to use model vs actual fees is context-dependent. While the marketing rule allows net performance to be calculated using either actual or model fees, there are cases where the use of actual fees may be misleading. The SEC emphasized flexibility and that while both fee types are allowed, what’s appropriate depends on the facts and circumstances of the situation, including the clarity of disclosures and how fee assumptions are explained.
Which Model Fee Should Be Used?
Most firms offer multiple fee structures, typically based on account size, but sometimes also on investor type (institutional versus retail clients). That variability makes fee selection a key decision when presenting net performance.
If you plan to use a single performance document for broad or mass marketing, best practice—and what the SEC Marketing Rule effectively requires—is to calculate net returns using the highest anticipated fee that could reasonably apply to the intended audience. This helps ensure the presentation is not misleading by overstating what an investor might take home.
A common pushback is: “But the highest fee isn’t relevant to this type of investor.” And that may be true. In those cases, firms have a few defensible options:
- Create separate versions of the presentation tailored to different investor types, or
- Present multiple fee tiers within the same document, clearly explaining what each tier represents
Either approach can work—but only if disclosures are explicit and easy to understand. When multiple fee structures are shown, clarity isn’t optional; it’s essential.
In practice, many firms maintain separate retail and institutional versions of factsheets or pitchbooks. That approach is perfectly reasonable, but it comes with operational risk. If this becomes standard practice, firms need strong internal controls to ensure the right presentation reaches the right audience. That means:
- Clear internal policies
- Consistent naming and version control
- Training marketing and sales teams on when each version may be used
This often involves an overlap of both marketing and compliance to get it right because getting the fee right is only part of the equation. Making sure the presentation is used appropriately is just as important to ensuring net performance remains meaningful, compliant, and credible.
Which Statistics Can Be Shown Gross-of-Fees?
Since the introduction of the SEC Marketing Rule, there has been significant debate about whether all statistics must be presented net-of-fees—or whether certain metrics can still be shown gross-of-fees. Helpful clarity arrived in an SEC FAQ released on March 19, 2025, which confirmed that not all portfolio characteristics need to be presented net-of-fees. The examples cited included risk statistics such as the Sharpe and Sortino ratios, attribution results, and similar metrics that are often calculated gross-of-fees to avoid the “noise” introduced by fee deductions.
The staff acknowledged that presenting some of these characteristics net-of-fees may be impractical or even misleading. As long as firms prominently present the portfolio’s total gross and net performance incompliance with the rule (i.e., prescribed time periods 1, 5, 10 years),clearly label these characteristics as gross, and explain how they are calculated, the SEC indicated it would generally not recommend enforcement action.
Bringing it all Together
On paper, presenting net and gross performance should be a straight forward exercise.
In reality, layers of regulation, evolving expectations, and heightened scrutiny have made it feel far more complicated than it needs to be. But complexity doesn’t have to lead to confusion.
When firms are clear about:
- Who they are communicating with,
- What that audience expects,
- What the performance is intended to represent, and
- Why certain assumptions were chosen
…the decisions around what gets presented become far more manageable.
Net returns aren’t about finding a single “correct” number. They’re about telling an honest, well-documented story. And when that story is clear, investors don’t just understand the performance—they trust it.
[1] 2020 GIPS® Standards for Firms, Section 2: Input Data and Calculation Methodology(gross-of-fees returns and treatment of transaction costs, including bundled fees).
[2] See SEC Marketing Rule 2 026(4)-1(a) footnote 590 as well as the SEC updated FAQ from January 15, 2026. Available at: https://www.sec.gov/rules-regulations/staff-guidance/division-investment-management-frequently-asked-questions/marketing-compliance-frequently-asked-questions
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Key Takeaways from the 28th Annual GIPS® Conference
The CFA Institute hosted its 28th Annual Global Investment Performance Standards (GIPS®) Conference on September 17-18 in San Diego, CA. As always, the opportunity to reconnect with industry peers and colleagues was a highlight. We are grateful to all the speakers and panelists who shared their insights. Here are some key takeaways we found valuable from this year’s event.
The SEC Marketing Rule
The SEC Marketing Rule continues to be a topic of discussion, especially as we continue navigating the nuances of the rule and its implications for investment performance advertising. During the panel discussion, two presenters clarified several points:
Model vs. Actual Fees
It seems that there is rarely a case when the use of actual fees will adequately satisfy the marketing rule. This is a major development as at least 30% of the participants in the audience claim to still be using actual fees in their marketing.
According to the SEC marketing rule, when calculating net returns you can use actual or model fees. However, to satisfy the general prohibitions, an advisor generally should apply a model fee that reflects either the highest fee that was charged historically or the highest potential fee that it will charge the prospect receiving the advertisement (not a reasonable fee or an average). Footnotes 590 and 593 further clarify that there may be cases when using actual fees would specifically violate the marketing rule.
Footnote 590: “If the fee to be charged to the intended audience is anticipated to be higher than the actual fees charged, the adviser must use a model fee that reflects the anticipated fee to be charged in order not to violate the rule’s general prohibitions.”
and
Footnote 593: “…net performance that reflects a model fee that is not available to the intended audience is not permitted under the final rule’s second model fee provision.”
As a result, we recommend that anyone using actual fees in advertisements compare their net returns to the net returns that would have been achieved using the highest fee a prospect would pay as the model fee. If your actual net returns result in materially better performance than what the performance would be using the highest model fee, this is likely problematic. The rules do not define materiality, but the panelists did provide an example where the difference was only 25bp and they indicated that would likely be considered material.
If you do not have tools for calculating model fees, don’t worry, we are here to help. Reach out to one of our performance experts if you need help calculating model fees - we have tools that can simplify this for you.
Showing Multiple Net Returns in a Single Advertisement
Standardized marketing materials that show multiple net return results (including net of actual fees) may be presented in a single advertisement. This seems like a change of tone from what we heard last year, but this greatly simplifies what we thought previously. Since the adoption of the marketing rule, firms have struggled with how to standardize marketing materials, especially when they have different fee schedules and investor types.
Many firms now manage several versions of the same marketing document that show only the gross-of-fee returns and net-of-fee returns relevant to the specific audience receiving the advertisement. This can be logistically challenging to manage. Based on the discussion and case studies provided, it seems that firms are permitted to create a single document that shows various net-of-fee returns based on the fees charged to different investor types. The example provided looked something like this:

This shift in approach may be a huge relief for firms that are managing multiple investor types and are trying to track and update performance under various fee schedules. If electing to do this, it is important to ensure the fee proposed for the prospective investor is clear – especially when presenting a table like this to a retail investor. It is essential that your prospects can easily identify the net-of-fee return stream that is applicable for them.
Attribution & Contribution – Which is Performance?
Attribution is not considered performance while contribution likely is. Because Attribution is not considered performance, the use of a representative account is generally accepted. However, careful consideration should be applied in selecting an appropriate rep account and documentation to support its selection should be maintained. While the performance-related requirements of the Marketing Rule may not apply, the overarching requirement for the advertisement to be “fair and balanced” applies and must be considered when determining what account to use to represent the strategy.
A separate case study discussed how to handle situations when the rep account closes. Using the old rep account historically and linking its data to a new rep account is considered hypothetical, so if your rep account ceases to exist, it’s best to re-evaluate and select a different rep account to be used for the entire track record of the strategy.
Presenting Sector Contribution Returns Net-of-Fees
When presenting extracted performance, such as contribution or returns at the sector-level, this is treated as performance and must be presented net-of-fees. Since some firms have been mistakenly reducing each sector by a prorated portion of the percentage fee when determining the net-of-fee results, the panelists emphasized that when netting down sector returns, firms must deduct the full percentage fee from each sector. If allocating the dollar amount of the fee, that would be prorated by weighting the dollar amount of the fee by the weight the sector represents in the portfolio, but prorating a percentage will not create the same result and will overstate the sector-level net-of-fee returns.
The following example was provided to demonstrate how to apply model fees to sector returns and contribution in an advertisement:

Private Fund Gross & Net Returns
The calculation of gross and net returns for private funds must be consistent. For example, you cannot report a gross-of-fee return that excludes the impact of a subscription line of credit while reporting a net-of-fee return that includes it. Firms must disclose the effect of leverage, specifying the impact of subscription lines of credit rather than just stating that returns will be lower.
Per the marketing rule: gross- and net-of-fee returns must be calculated over the same time period, using the same type of return methodology. For example, it is not appropriate to calculate gross IRR using investment-level cash flows and net IRR using fund-level cash flows as that would be considered different methodologies.
Hypothetical Performance
Firms should be prepared to defend the classification of hypothetical or extracted performance. Hypothetical performance is defined as “performance that no specific account received.” Panelists made a point of noting that the return stream of a composite is not considered hypothetical, even though no specific account received the performance.
Along similar lines, a case study was presented where a firm wanted to show recommended funds to an existing client in a marketing presentation. The question was whether presenting a recommendation like this is considered hypothetical. Not surprisingly, the answer was “it depends on how the information was presented.” Presenting the information in a way that implied what the investor “could have received” would likely be hypothetical. Simply showing how these funds performed historically (so long as it complies with the marketing rule – showing prescribed time periods etc.) appeared acceptable.
AI in Investment Performance Reporting
The integration of AI into performance measurement and reporting continues to gain momentum. Of particular interest was how quickly our jobs may be changing and whether we need to be concerned about job security.
Jobs that focus on data gathering, prepping and cleaning are expected to be replaced by AI in the near future. We’ll likely see fewer new job postings for these entry-level roles, with a shift towards more value-added positions, such as data scientists, becoming more prevalent. Panelists suggested that many roles within the performance measurement function, including auditing, will likely be augmented, automating repetitive tasks (often performed by more junior professionals) and enhancing data analysis functions. Higher-level human oversight will still be essential for exercising judgment and interpreting information within the context of real-world scenarios – at least for now.
Panelists recommended preparing performance teams by encouraging them to take basic courses in Python and SQL to help prepare and empower them for the shift to a future with AI. AI platforms already exist that can perform detailed performance attribution and risk assessments by simply asking a question – much like one would with ChatGPT. It is likely that performance measurement professionals will continue to be needed to develop these platforms, and they will likely remain reliant on some human oversight for the foreseeable future.
Updates on the GIPS Standards
There were not a lot of updates on the GIPS Standards at the conference. As of July 31, 2024, 1,785 organizations across 51 markets claim compliance with the GIPS standards. This includes 85 of the top 100 global firms, and all 25 of the top 25 firms. The top five markets include the US, UK, Canada, Switzerland, and Japan, with Brazil emerging as a new market entrant in 2024.
The conference also provided updates on recent changes to the GIPS Standards. Key updates included:
- The Guidance Statement for OCIO Strategies will be released by year-end, providing more clarity for firms managing OCIO portfolios. It appears that gross-of-fee and net-of-fee returns will need to be presented for OCIO composites.
- The Guidance Statement for Firms Managing Only Broadly Distributed Pooled Funds(BDPFs) became effective on July 1, 2024. The new guidance offers increased flexibility for firms managing BDPFs, allowing them to avoid preparing GIPS Reports for prospective investors and instead focus on reporting for consultant databases or RFPs. While input data and return calculation requirements generally still apply, composite construction and report distribution are only required if the firm chooses to prepare GIPS Reports.
- The GIPS Technical Committee is forming a working group to address after-tax reporting. For now, firms should refer to the USIPC After-Tax Performance Standards, which were issued in 2011. Additionally, as there is little consensus on how to calculate private fund returns, the committee plans to provide further guidance—though a timeline was not specified.
These takeaways underscore the evolving nature of the investment performance landscape. If you have any questions, please don’t hesitate to reach out to us. We would be happy to share additional insights from the conference as well as jump start your firm in complying with the GIPS Standards.
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.

Are ETFs A Better Benchmark?
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.

Key Takeaways from the 2024 PMAR Conference
We at Longs Peak Advisory Services were thrilled to sponsor and participate in the 22nd Annual Performance Measurement, Attribution & Risk Conference (PMAR™) held on May 22-23, 2024. The event was a fantastic opportunity for us to engage with industry experts and share our insights. We always appreciate how TSG encourages participants to engage with sponsors and if you were there, hope we had a chance to meet you!
If you couldn’t make it this year, here are some of the key takeaways from the event that we found most impactful:
Artificial Intelligence in Performance and Reporting
This year’s event included two powerful sessions on the use of AI in the performance industry. Harald Collet from Alkymi presented a compelling session on the transformative impact of artificial intelligence (AI) in performance measurement and reporting. AI's capability to process vast amounts of data and generate actionable insights is indeed revolutionizing our field. Collet's discussion highlighted both the opportunities AI presents, such as enhanced efficiency and accuracy in reporting, and the challenges it brings, including concerns about data integrity and ethics. This session resonated with us as we continually seek to integrate advanced technologies to better serve our clients while carefully managing associated risks.
The application of AI, even on a small scale, can have a profound impact, helping optimize processes, and enhancing customer/employee experience and overall satisfaction. It has the power to enhance productivity and decision-making, making even modest use of this technology extremely valuable. One example provided was how to integrate AI with Excel. It is now possible to augment Excel’s capabilities to automate data entry, cleaning, and formatting, which saves time and reduces human error.
The “human in the loop” (HITL) concept was also discussed which emphasizes the role of human oversight and intervention in AI systems, where AI technologies are guided and corrected by human judgment, particularly in complex or critical tasks where machine errors could have significant consequences. While experts in many fields are often concerned that AI technologies will replace individuals in the workforce, Collet encouraged the crowd with a simple reminder that “You’re not going to lose your job to AI. You’re going to lose your job to someone who is using AI.”
Implementing SEC Guidelines
Our very own partner, Matt Deatherage, CFA, CIPM, had the privilege of moderating a session on the practical implementation of the new SEC guidelines alongside Lance Dial and Thayne Gould. They aimed to provide attendees with a comprehensive overview of these guidelines and share strategies for effective compliance. Now that the guidelines have been in place for over a year, the discussion underscored the importance of understanding regulatory expectations and adapting internal processes accordingly. Some of the key reminders from this session were:
- Most of the time the SEC will likely view Yield as a performance statistic and should therefore be shown net of fees. If the investment firm believes yield is not performance and wants to show it gross, they must be comfortable in defending that stance.
- Attribution analysis is often seen as performance-related information and therefore needs to be net of fees.
- Do not put hypothetical performance on your website! In most scenarios, it is generally not appropriate to present hypothetical performance. This is also a relevant topic in current events, where organizations have been fined for adding hypothetical performance to their website.
- Any sort of statement made in marketing needs to be supported. For example, if a firm claims to be “the best” they need to be able to support that claim – according to what/whom are you the best?
- A MWR (“also known as “IRR”) stream must also be presented with the prescribed time periods, net of fees. As of this publish date, the SEC has not put out any prescribed calculation methodology on how the MWR is to be calculated.
This panel offered actionable insights to help firms navigate the regulatory landscape efficiently and ensure adherence to the latest SEC standards. Reach out if you would like us to connect you with an SEC compliance consultant.
GIPS® Standards OCIO Guidance Statement
One of the standout sessions was the panel discussion on the Global Investment Performance Standards (GIPS®) OCIO Guidance Statement, featuring Joshua O’Brien, Todd Juillerat, Amy Harlacher, and G.R. Findlay. This session was invaluable as it delved into the implications of the guidance for firms managing outsourced chief investment officer (OCIO) services. While there is still some gray area around the OCIO guidelines, the panel emphasized the necessity of aligning with global best practices and provided insight into the important considerations to keep in mind for compliance. It reinforced the importance of transparency and consistency in performance measurement, which are core values we uphold at Longs Peak.
GIPS® Compliance Q&A
In another interactive session, Matt Deatherage joined John D. Simpson, John Norwood, and Susan Agbenoto for a Q&A on GIPS® compliance. They addressed a variety of common questions and concerns, providing practical advice for firms striving to adhere to the GIPS® standards. Some of the questions they answered were:
Q: What are some best practices to prepare for a verification?
A: Outlier reviews are extremely important to make sure composite construction is accurate and in line with expectations and your policies and procedures. Performing this type of review can help catch composite construction mistakes that may otherwise delay a verification if found in the testing process. This review is important no matter the approach you take as outliers can be reviewed in a variety of ways.
Never done an outlier review? Fill out this form and put PMAR2024 in the message box -- we will test a sample of your composite data and provide you a list of outliers for review.
Q: What should be reviewed annually by a GIPS compliant firm?
A: GIPS standards policies and procedures. Your policies and procedures are the backbone to your claim of compliance and should be reviewed periodically to ensure they are still up to date. Reviewing this at least annually and documenting any changes will go a long way.
Q: What tips do you have for firms looking to become GIPS compliant or adjust their current compliance program?
A: We have lots of suggestions, but here are two big ones:
- Leverage software as much as possible, whether that be for composite construction or GIPS report creation. Software can help build efficiencies and remove risk of human error.
- Don’t over-complicate your compliance program or policies and procedures. Make sure your policies and procedures are meaningful, but not so complex that they become difficult to consistently follow and implement.
What resources are available for organizations going through verification (whether it’s their first or 10th)?
A: While it can be helpful to appoint someone internally as the head of your GIPS compliance program to oversee all relevant requirements are being met, depending on the size of your organization, you might need to seek out additional help if you have no one in-house with this knowledge. We have helped over 150 firms become GIPS compliant by serving as their outsourced GIPS standards experts and would love to support your firm too.
There are also third parties, such as your verifier, that can help answer questions about GIPS standards verification. The CFA Institute also has a lot of great resources available such as the GIPS standards help desk (email them at: gips@cfainsitute.org), GIPS handbook and/or the GIPS standards Q&A Database.
We hope this session was rewarding for participants and left them with clear takeaways for enhancing their GIPS compliance practices.
WiPM Event
For the second year in a row, the Women in Performance Measurement (WiPM) group hosted a meaningful and enlightening day-long event in conjunction with PMAR. With sessions addressing communication in the workplace, ethical considerations in performance, and work-life balance, the conversations and knowledge-sharing did not disappoint.
It was inspiring and encouraging to hear from so many female thought leaders engaged in discussion about how we can further equip the next generation of female leaders in performance measurement. Two key highlights from the women-focused content shared included:
- The importance of creating a “brag book.” Oftentimes as women, it can feel arrogant or uncomfortable to share successes, but it’s important to remember that we can be our biggest advocates when we keep a record of our own accolades and triumphs. While the title of “brag book” could be off-putting, it is intended to simply be a “fact book” of all the accomplishments you’ve had in the workplace.
- Especially for women, work-life balance can feel impossible to achieve, so we explored the idea of “work-life harmony” instead. We discussed how the idea of “work-life balance” always feels like a give and take where one area has to give for the other area to grow – causing women to feel more guilt around the area that is now lacking. When we reframe this topic to be “work-life harmony,” it allows us to think about work and life in tandem – ebbing and flowing with a level of musicality that doesn’t require one to be “less” for the other to be “more”, but rather gives women the ability to recognize how they can be successful in both areas of life as the demands of each shift in different seasons.
While WiPM is still a relatively new organization, the group is excited to continue to offer group and individual programs to aid in the advancement of women in the performance measurement industry. During the event, the group highlighted the existing Mentoring program that matches mentors/mentees together to support one another in their performance-related careers.
Conclusion
PMAR™ 2024 was a resounding success, offering a wealth of knowledge and practical insights on the latest advancements and regulatory updates in performance measurement and risk management. Our sponsorship and active participation underscored our commitment to supporting the industry's growth and evolution. We at Longs Peak are dedicated to advancing best practices and helping our clients navigate the complexities of performance measurement and GIPS compliance. If you have any questions about the 2024 PMAR Conference topics or GIPS and performance in general, please contact us.
We hope to see you at PMAR & WiPM in 2025!

How to address Yield in Marketing: SEC Marketing Rule
The SEC's Marketing Rule, Rule 206-4(1), outlines specific criteria for the disclosure of "performance." However, determining whether metrics like yield constitute "performance" under this rule seems ambiguous. Based on our experience, yield information falls into one of three categories:
- Performance - prompting the Marketing Rule's requirements;
- A portfolio characteristic – exempt from the performance presentation rules; or
- Both
While SEC staff have discussed this ambiguity publicly and privately, a definitive stance on the treatment of yield in advertisements remains elusive. In practice, presenting the actual yield of an account or composite often qualifies as performance, as it aims to demonstrate the income generated and expected.
Conversely, the yield of an individual investment, such as a specific bond, could be considered a characteristic, especially when presented alongside other metrics like duration and maturity.
Determining if yield should be considered performance or characteristic may also depend on its intended use and the overall context. For instance, displaying the average yield of investments as part of a risk assessment suggests it may be a characteristic, while presenting the portfolio's yield likely implies performance under the Marketing Rule. Similarly, the yield of an individual investment may be deemed a characteristic or "extracted performance" based on context.
You may also want to consider the significance of yield to the performance presented as this could also determine how the SEC may interpret the information. During the 2023 GIPS Standards Conference, extensive discussion was had about the significance of yield to strategy performance. For example, the yield of a bond portfolio may be more likely considered performance while dividend yield, presented for a large cap equity portfolio, could be regarded as a characteristic.
What to do
To navigate this ambiguity, we recommend that firms pre-determine whether a metric is intended as performance or a characteristic and document this decision and reasoning internally. If yield is deemed a characteristic, marketing materials should reflect this classification and include appropriate disclosures. All presentations should include comprehensive performance disclosures, including gross and net figures over relevant time frames.
Although SEC staff interpretation may differ, internal documentation and disclosure can mitigate regulatory risks unless expressly contradicted by SEC guidance.


Longs Peak 2023 Highlights: Reflecting on a Remarkable Year
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!


Key Takeaways from the 2023 GIPS® Standards Conference
CFA Institute hosted the 27th annual GIPS Standards Conference on October 17th - 18th 2023 in Chicago, Illinois. As expected, it was filled with a lot of familiar faces, but also had quite a few first timers, which was nice to see.
Being almost a year into the SEC Marketing Rule and with implementation of the Private Fund Adviser Quarterly Statement Rule on the horizon, the hottest topics of this year’s conference were the sessions relating to regulatory compliance. These sessions included discussions with representatives from the U.S. Securities and Exchange Commission (“SEC”) answering practical questions related to adherence to these rules as well as sessions with senior performance professionals discussing the detailed performance methodology required to comply.
Other topics included a review of the proposed guidance statement for applying the GIPS standards to OCIOs, helpful advice for updating consultant databases, a proposed method to risk-adjust performance attribution, and some lessons on soft skills for leaders managing relationships.
SEC Marketing Rule
Michael McGrath, CFA, Partner with Dechert LLP and Robert Shapiro, Assistant Director, Division of Investment Management with the SEC together with Karyn Vincent, CFA, CIPM and Krista Harvey, CFA, CIPM of CFA Institute did an excellent job emphasizing the key lessons learned as we near the 1-year mark of the adoption of the Marketing Rule. Below are some key takeaways worth noting:
Defining “Performance”
Since the Marketing Rule requires investment managers to present performance net-of-fees, it is important for firms to define what they consider “performance.” The SEC takes a straightforward approach, generally considering any statistic that demonstrates how much an investor earned from an investment to be performance. But, even with this simple and easy to understand approach, there can be some grey areas.
Based on the discussions in this session, it seems to now be widely accepted that in addition to basic returns being considered performance that contribution is also considered performance, while attribution and most performance appraisal measures are not considered performance. Performance appraisal measures should be individually considered to confirm if they are demonstrating the amount earned (which would be performance) or if it is used as a measure of the manager’s skill(which would not be considered performance).
Some portfolio characteristics could also be a grey area that firms should be careful to consider before presenting solely as gross-of-fees. For example, yield was discussed at length. It was said that total portfolio yield for something like an enhanced cash portfolio likely would be performance because the yield in that case is essentially the return the investor earned. On the other hand, dividend yield for a growth strategy where this does not directly indicate the amount the investor earned *might* be performance. This really would come down to how it is presented and how material the yield is to the strategy. If material to the strategy’s return, this may be considered performance and, in this case, would need to be reduced by a model fee.
After determining that a statistic is not performance and will be presented based on gross-of-fee input data, it is important to clearly label these figures as gross. A disclosure under the table or chart that simply states something like, “Risk statistics are presented gross-of-fees,” should suffice.
There was also a lot of discussion relating to applying fees to extracted performance such as sector and holdings-level performance. It was made very clear that each segment must be reduced and presented net-of-fees so fees cannot just hit the cash segment or something like that. To achieve this, most firms are using a model fee. For example, if the highest fee for the strategy is 1% per year and quarterly sector returns are presented, each sector’s quarterly return is reduced by 0.25%.
Hypothetical Performance
Hypothetical performance has been a focus of the initial SEC enforcement actions taken against firms under the Marketing Rule. The main issue has been firms broadly distributing hypothetical performance without any policies and procedures in place to ensure the distribution of this type of performance is limited only to those that can be reasonably expected to understand it.
The key is that firms must document policies that clearly define the intended audience for a particular presentation of hypothetical performance and then ensure that the presentation only goes to this audience. In addition, documentation should include the tools necessary to understand the information provided. For example, the type of hypothetical performance should be clearly described as well as any assumptions made to create this performance.
Hypothetical performance is very broadly defined. It could be anything from a back-tested model to a paper portfolio or even just an aggregation of extracted returns (e.g., a composite of carveouts). It should be clear what the performance represents and consideration should be given to the complexity of the information, especially when determining it’s appropriate audience.
Private Fund Adviser Quarterly Statement Rule
Anne Anquillare, CFA, Head of US Fund Services with CSC Global Financial Markets and Pamela Grossetti, Partner with K&L Gates together with Krista Harvey, CFA, CIPM of CFA Institute walked us through the key elements to prepare for with the new Private Fund Adviser Quarterly Statement Rule. Below are some key takeaways worth noting:
The Compliance Date for the Quarterly Statement Rule is March 14, 2025. This may sound like a long time away, but it is important to keep in mind that the requirement to include cross-references to the underlying governing documents in the Quarterly Statement may require amendments to such documents before the first Quarterly Statement is issued, and this could be time consuming.
Under this new rule, private fund managers must distribute a quarterly statement to the investors in the fund within 45 days after each quarter ends and 90 days after year-end. This is required for any private fund that has at least two full quarters of operating results.
There are many items that must be included in the quarterly statements relating to general fund details like fees and expenses as well as disclosures that are cross-referenced to the private fund’s offering documents; however, being the GIPS conference, this presentation was primarily focused on the performance requirements.
The performance requirements for liquid funds are very different for illiquid funds. An illiquid fund is one that is not required to redeem interests when requested by an investor and has limited opportunities for an investor to withdraw funds prior to the fund’s termination. If a fund manager determines that their fund is liquid, the performance requirement for the quarterly statement is limited to showing the following three items, each in equal prominence:
- Annual net-of-fee returns for each of the past 10 fiscal years (or back to inception if shorter)
- Annualized net-of-fee returns for the past 1, 5, and 10 years through the end of the latest fiscal year (or since inception if shorter)
- Year-to-date net-of-fee return for the current fiscal year
Illiquid funds have a much more significant requirement with 12 figures they are required to present:
Portfolio-Level

Investment-Level

Unlike the GIPS standards, under this rule, there is no exemption for funds that only use a subscription line of credit for a short period of time. Funds that utilize a subscription line of credit for any period are required to show the metrics listed above both with and without the subscription line.
Another notable difference from the GIPS standards is that this rule requires interest expense charged from the subscription line of credit to be added back when calculating the “without subscription line of credit” version of the required metrics. The GIPS standards do not require this adjustment.
It was also discussed that if these quarterly statements were provided to prospective investors instead of only current investors then they would also need to be reviewed to confirm that they meet the Marketing Rule on top pf the Quarterly Statement Rule.
Current State of SEC Exams
Mark Dowdell, Assistant Regional Director with the SEC together with Ken Robinson, CFA, CIPM from CFA Institute discussed current trends in SEC examinations. Below are some key takeaways worth noting:
There was a strong emphasis on the need for clear policies and procedures that have been customized for the firm. Specifically, it was emphasized that policies and procedures relating to hypothetical performance are not the only thing firms should make sure they add for the Marketing Rule. For example, if firms are presenting predecessor performance or extracted performance there should be documented policies for this as well.
It was mentioned that in addition to standard examinations, the SEC is also conducting some risk-based exams that may be limited in scope, but go very deep on a narrow area. This may even include the recalculation of performance in their own systems to get comfortable with the accuracy of presented figures.
Outside of the recent enforcement actions relating to hypothetical performance, the SEC continues to see firms make exaggerated or untrue statements relating to the number of staff they employ, the qualifications of staff, awards received, the use of AI in the investment process, and their adherence to ESG standards in the investment process. While it is okay to state opinions in marketing materials, statements of fact absolutely must be substantiated.
Developing a Database Strategy
Jill Banaszak, Global Head of Omni Success at eVestment lead a great session on getting the most out of 3rd party and consultant databases.
The most important takeaway was the importance of using databases to tell the story of your firm in a complete and accurate way. Often firms leave a number of fields blank or neglect to revisit (or update) the narrative sections to remain accurate and in sync with their other messaging online or in marketing materials. Asset owners and their representatives use the databases to make short lists of firms meeting their criteria and many firms end up excluded as a result of blank fields or inconsistencies in messaging. At a minimum, firms should target completing at least 80% of the requested information.
It is also important to ensure information is completed timely and accurately. Firms should have monthly figures updated by the 12th business day of the month at the latest to avoid missing out on searches. To avoid errors or incomplete information, firms should consider who is tasked with updating the information and also ensure this person or team is qualified and has access to all relevant information so it can be fully completed. Implementing a quality control process to double check the information is also important to avoid typos or other mistakes in the information presented.
Applying the GIPS Standards to OCIOs
There is currently an exposure draft of the Guidance Statement for OCIO Strategies out for public comment with comments due by 20 November 2023. This session was led by a group of panelists who were part of the OCIO working group that created this new guidance statement. The purpose of this guidance statement is to improve comparability between OCIO strategies. The primary change in this proposed guidance that deviates from the current requirements of the GIPS standards for firms is the required composite structure that all OCIO managers would need to follow.
The required composite structure would separate liability-focused composites from total return objective composites and would then further break the composites down by their allocation between risk mitigating assets and growth assets ranging from conservative to aggressive allocations. There are specific weightings defined for each that are intended to line up with commonly used OCIO benchmarks.
These new composites are only required to build out five years of history, but like other composites firms manage, must then build up to showing a ten year track record before any performance periods can be removed.
This guidance statement also proposes requiring both gross-of-fee returns and net-of-fee returns instead of only one because of the complexity of OCIO fees.
This guidance statement has not yet been officially adopted, but once approved, it is expected to allow for a 12-month implementation period for firms to update their policies and procedures, construct composites that align with the prescribed composite structure, and create GIPS reports for these new composites.

Conclusion
This year’s speakers did a great job providing clarification on the SEC Marketing Rule and other relevant topics that impact GIPS compliance and investment performance.
We were happy to see many old friends in person this year in Chicago and look forward to seeing everyone again next year in San Diego. It was announced that next year’s conference will be held on the 17th – 18th of September in San Diego, California!
If you have any questions about the 2023 GIPS Standards Conference topics or GIPS compliance and performance measurement in general, please contact us.
*A previous version of this article included a mistake for investment-level figures for illiquid funds. This has been corrected.

Top 5 Risk Statistics to Include in Your Factsheets
We all know that investing involves a delicate balance of seizing opportunity and managing risk. Even if you do it well, your factsheet may not adequately explain how your strategy manages that balance. Your factsheets tell the story of your performance history and play a crucial role in your sales process by helping prospective investors make informed investment decisions. But how do you know if you’ve included the right information?

Types of Measurements
While every strategy differs in terms of its investment objective, it’s important to identify which types of statistics will be the best at helping you tell the story behind your investment strategy.
Before you choose the exact statistics to include, take a moment to think through what makes your strategy unique and then consider the audience you’re speaking to (sometimes this may mean making more than one factsheet for the same strategy – think retail vs. institutional).
Here are the main categories that should be included…
- A measure of volatility – to demonstrate stability (or variability) of your strategy
- Correlation – to express sensitivity to the benchmark or market
- Risk-adjusted returns – to standardize performance evaluation when considering risk
- Downside risk – to explain how your strategy performs in down markets
- Market Capture – to display how the strategy performs during market movements (up or down)
Only you know what makes your strategy unique and appealing to prospective investors, so take the time to determine the key pillars of your strategy and then select statistics that help demonstrate or reinforce that story.
Once that’s clear, it’s time to crunch some numbers.
Top 5 Risk Statistics
Here’s a list of the top 5 risk statistics our experts see included on our clients’ factsheets.
1. A Measure of Volatility: Standard Deviation
Investment managers have different ways of measuring volatility – often dependent on the strategy employed. Most commonly, we see standard deviation used, which is a measure of total risk (i.e., both systematic and unsystematic risk). Standard deviation quantifies the variability of a strategy’s returns from its average over a specific period. A higher standard deviation indicates greater volatility, implying that the strategy’s returns have experienced significant fluctuations or high variability.
Standard deviation is generally presented for both the strategy and a comparable benchmark. Risk-averse investors are generally looking to invest in strategies that achieve higher returns than the comparable benchmark while having a lower standard deviation than the benchmark over the same period.
Be sure to use this measure to demonstrate the stability of your strategy when it is historically low or to attract those with higher tolerance for fluctuation when it has been historically high. An explanation about how that higher fluctuation translates into outperformance will help paint a more complete picture.
2. Strategy Correlation: Beta
When assessing a new strategy, investors often want to consider how the strategy will fit into their broader portfolio. One way to evaluate this is by considering how sensitive the strategy is to the market (or the total portfolio’s benchmark) using beta. When armed with this information, investors can determine if adding your strategy would increase or decrease their exposure to the pulse of the market. If your strategy intends to offer diversification benefits, beta should be less than one (or negative). If you are adding market exposure, it should be greater than one.
In factsheets, we commonly include beta, calculated against the strategy’s benchmark, to show how the strategy moves relative to its benchmark. This is useful for investors to see if the calculated beta aligns with how an investment manager has described its investment process.
For example, for a strategy described as a “bottom-up approach that holds a concentrated portfolio of the best-performing stocks from a larger universe” (and therefore not directly tied to an index), we would expect beta to be very low (or even negative) or very high, but not close to 1. If it is close to 1, they may be a “closet indexer” that claims to have an in-depth research process, uncorrelated with the market, but in reality, is still basically replicating the benchmark. Investors would want to know this because they can invest in ETFs or funds designed to replicate a benchmark for much lower fees.
Conversely, for a strategy that is described as "enhanced indexing," beta should be close to 1 with returns that outperform the index. In this case, the goal is to track the risk level of the index while beating it performance-wise.
In either case, investors want to see strategy metrics support how your strategy and process is described. If any of these risk measures don’t align, we recommend taking the time to understand and explain why.
3. Risk-Adjusted Returns: Sharpe Ratio
While arguably the most common risk statistic to include, the Sharpe ratio is helpful as a comparison tool because it standardizes performance and risk into one measure.
The Sharpe ratio demonstrates a strategy’s risk-adjusted return by considering its excess return (return above the risk-free rate) per unit of risk taken (standard deviation). A higher Sharpe ratio is preferred. If your strategy claims to offer superior returns with lower risk, the Sharpe ratio is an appropriate measure to demonstrate that.
However, keep in mind that this measure may not be useful for strategies that are not normally distributed (e.g., hedge funds or other strategies with returns that are materially positively skewed when the strategy is successful). For most traditional investment managers, especially those targeting institutional investors, this measure is often expected on a factsheet, so don’t overlook it.
4. Assessing Downside Risk: Maximum Drawdown
Maximum drawdown measures the largest peak-to-trough decline in a strategy’s performance over a specific period. This metric is crucial because it quantifies the potential loss an investor could have experienced during the strategy’s worst-performing period. A larger maximum drawdown implies higher downside risk.
This measure is often good to show along with the max drawdown of the market or benchmark for comparison. While higher potential returns often correlate with greater downside risk, investors, equipped with this information, can determine their tolerance for this kind of loss. In addition, they can use it to compare to other similar strategies they are considering.
If your strategy claims to manage downside risk, maximum drawdown is arguably the best measure to demonstrate tactful management during down markets.
5. Market Capture: Upside/Downside Capture
These measures assess how well a strategy or portfolio performs during market movements, specifically in comparison to a benchmark. Upside capture measures the degree to which a strategy captures the positive returns of a benchmark during periods of market growth. Downside capture measures the degree to which a strategy is exposed to losses when the benchmark declines.
These capture ratios can be used to explain how a strategy aims to achieve specific goals related to market conditions. For example, “beats the market on the upside and protects on the downside” (you’d hope to see over 100% upside capture with less than 100% downside capture) or “capital preservation with risk targets below the overall market” (you’d expect to see lower than 100% upside capture with hopefully a very low downside capture).
Please note that it is most common to show these measures together (or to show total capture ratio that combines the two). Considering the “fair and balanced” requirements in the SEC marketing rule, it’s likely prudent to include both to explain the full picture.
For an aggressive strategy that is over 100% capture both on the upside and the downside or a capital preservation strategy that is under 100% both on the upside and downside, you ideally can still show that the total capture ratio is greater than 1. This demonstrates that the strategy is winning on the upside by a greater amount than it is losing on the downside or that protection on the downside more than offsets the lagging performance on the upside.
Conclusion
When it comes to investing, knowledge is power. Factsheets provide investors with valuable information to help them make informed decisions about your firm and strategies. When you provide them with a full picture of your performance that includes risk, they are more fully equipped to consider you for further due diligence.
Investment firms that understand these statistics and use them to help explain the story of their investment performance provide context and transparency in a saturated landscape of investment options.
Make sure to take the time to understand what these measures say about your performance each period and include that in some form of market commentary when you share your factsheets with prospects. This demonstrates how informed you are about the strategies you manage, how decisions made impact results, and what your plans are to address them.
Want to discuss how you can improve your factsheets with risk statistics? Schedule a free 30-minute brainstorm with one of our partners on which statistics you should include to help explain your investment performance.

Live Your Best Life: A Note from Sean
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!

GIPS Compliance in Marketing Materials: Demonstrating Your Competitive Advantage
In today's highly competitive financial landscape, your company must stand out and demonstrate its commitment to transparency and accuracy. One powerful tool at your disposal is the Global Investment Performance Standards (GIPS®).
We know how complicated it can be to become GIPS compliant and that’s exactly why we built Longs Peak – to do the heavy lifting for firms and simplify the verification process. By allowing us to tackle the behind-the-scenes work, we’ve helped hundreds of firms become compliant at a much faster rate than if they’d handled it internally – giving them the opportunity to quickly leverage their GIPS compliant status in their marketing and messaging.
By becoming GIPS compliant and incorporating GIPS compliance into your marketing materials, such as factsheets and pitchbooks, you can strengthen your credibility and trustworthiness among clients and prospects.

Let’s explore how to effectively utilize the GIPS standards in your marketing to help highlight your competitive advantage.
Understanding GIPS Compliance & Its Benefits
Before delving into marketing, let's review the fundamentals of GIPS compliance. The GIPS standards are a globally recognized set of ethical principles that provide a standardized framework for calculating and presenting investment performance to prospective investors.
By complying with the GIPS standards, you demonstrate that your performance results are genuine, comparable, and fairly presented. Moreover, GIPS compliance promotes transparency and instills confidence in potential investors, enhancing your marketability.
Highlighting Your Firm’s GIPS Compliance
After going through all the hard work to become GIPS compliant, it is important to share that status with the world so you can reap the benefits of your efforts! By including information about your firm’s GIPS compliance in your marketing, you instantly communicate your dedication to adhering to global best practices.
Trust is so important in the investment industry. By explaining how your firm is going above and beyond regulatory requirements to ensure your investment performance is presented in a fair and transparent manner helps demonstrate your firm’s trustworthiness and can help you stand out in an oversaturated landscape of options.
Tailoring the Message to Different Audiences
With any marketing effort, it’s important to consider your target audience. Understanding the needs, preferences, and concerns of that audience allows you to speak directly to their interests, fostering stronger connection and engagement.
When mentioning GIPS compliance, keep in mind that retail investors may be less familiar with the Standards and therefore may need more information to understand the benefits. Institutional investors tend to know about the Standards and likely need less explanation. By employing language that resonates with the target audience, you not only capture their attention but further build credibility and trust.
Advertising Your Firm’s GIPS Compliance
Now that we have emphasized the importance of highlighting your firm's GIPS compliance in your marketing materials, it is important to consider how this should be done. When mentioning GIPS compliance, there are some very specific disclosures that must be included. It is important that your firm does not state or imply that your firm is GIPS compliant without these disclosures.
Firms mentioning GIPS compliance in their marketing have the option either to follow the GIPS Advertising Guidelines or to attach a GIPS Report for the relevant composite or fund being marketed. You can download our checklists of what disclosures to include when following the GIPS Advertising Guidelines or when creating GIPS Reports.
For any marketing piece that includes a GIPS Report, we encourage firms to create a standalone page for the GIPS Report. The GIPS standards have specific requirements for reporting errors on the GIPS Report, so you want to limit information on that page to only what’s required and avoid the potential of having to report errors that could have been avoided if the information was kept separate.
Using Visuals to Enhance Understanding
GIPS Reports and their required disclosures tend to leave marketing teams feeling creatively stifled. But the goal of a good marketing presentation is to be engaging and digestible. Graphs, charts, and infographics can help convey complex performance data with clarity and impact.
Visual representations can be especially effective in illustrating return data and depicting how your strategies have outperformed benchmarks (i.e., growth of dollar line chart) over time. However, always ensure that the visual representations are aligned and never conflict with the information presented within the GIPS Report.



Incorporating Risk Statistics
Of course, no investment performance presentation is complete without discussing risk. There are a variety of risk statistics that can (and should) be used to demonstrate how each strategy you manage performs relative to risk. If you want to learn more about what risk statistics to include, you can read about the most common ones we see here.
Showcasing the Competitive Advantage
Beyond GIPS compliance, highlight the distinct features that set your investment strategies apart from the competition. Emphasize your expertise, team capabilities, and successful track record. While GIPS compliance is a powerful differentiator, showcasing your unique approach to investment management will further position your firm as a top choice for potential investors.
Wrap Up
By incorporating GIPS compliance into your marketing materials, you signal a commitment to transparency, accuracy, and investor protection. Emphasize the benefits of GIPS compliance, use visuals to enhance understanding, incorporate a discussion about risk and spotlight your competitive advantage. With these strategies in place, your marketing materials will become powerful tools for attracting and retaining investors, ultimately propelling your company to new heights of success.
Are you ready to leverage the power of GIPS compliance in your marketing materials? Schedule a call with one of our partners to elevate your credibility with investors and gain a competitive edge. Let us help you get started!


