Around the Peak.

Every so often we hear it: "Oh, you're one of the performance software tools."
It's an understandable assumption. We work in the same world as the software providers: composites, Global Investment Performance Standards (GIPS®), performance data, and the systems that produce all of it. From the outside, it can look like we're all selling the same thing.
We aren't. And if you're deciding how to support your performance and GIPS compliance work, the difference is worth understanding.
The short version: Longs Peak is a team of people who do the work with you, or for you. We're not a platform you log into. Behind the scenes, our tools help our team deliver faster, more consistent service. But no number leaves our hands without a real performance expert standing behind it.
Software Gives You a Capability. Someone Still Has to Run It.
A software provider hands you a tool. A good one can be powerful, and those systems offer a ton of capabilities. But once the tool is installed, the work to run it lands on your desk.
Someone on your team still has to load the data, set up and maintain the composites, review the results, chase down the account that looks off, and know the GIPS standards well enough to make the judgment calls. Software can calculate a return. It can't decide whether a new account belongs in a composite, explain why a number moved, or figure out what to do when a custodian changes its data feed.
What We Actually Do
At Longs Peak, we get our hands dirty, so you don't have to. In practice, that means:
- We manage your composites. Membership decisions, inclusion and exclusion, periodic updates, and the returns that come out the other end. We work alongside members of your team to get those questions answered and make the updates for you. The work gets done by a person who does it every day.
- We act as your GIPS expert. When a new strategy launches, a policy needs revisiting, or a gray area comes up, you have someone who knows the standards and has seen the situation before.
- We dig into your data. We look for outliers, accounts that are breaking composite rules, and other anomalies, before they end up in your reported performance and get caught in verification. Not only do we help identify potential issues, but we work with your team to help create the paper trail to provide an explanation if questioned by a verifier.
- We help with system issues. When your system isn't producing what you need, we get inside it and help work out why.
- We design the output. Once the data work is done, we turn it into beautifully designed, client-ready factsheets and reporting. And we understand this information from a performance, compliance, and design perspective.
- We help you communicate what matters most. For your prospects or a board of directors: which statistics support your story, and which just add noise? Those are communication choices, and we help you make them.
None of this is advice delivered from a distance. We maywork with you as a remote team, but we're not remotely hands-off. We work insideyour data, your systems, and your deadlines, the same way a colleague down thehall would. And when something needs fixing, we roll up our sleeves and fix it,so it’s off your plate and your to-do list.
Ways to Work With Us
Every firm is set up differently, so we don't force a single model.
- Fully outsourced. We run composite management on your behalf, start to finish. For firms without a dedicated performance team, this is often the cleanest answer.
- Part of your team. We work alongside your people, taking on the pieces that are heavy, specialized, or just hard to staff. To your colleagues, we're simply part of the performance team.
- Your GIPS expert on call. Your team runs the day-to-day, and we're there for the questions, reviews, and judgment calls that need someone who has seen it all before.
- Your marketing team. Your data is done and ready to be put to work. We turn it into polished factsheets and reporting for prospects, consultants, and boards, and help you decide which parts of your story deserve the spotlight.
Many clients start in one place and shift as their needs change. That flexibility allows us to grow alongside you and offer as much or little support as you need.
Why This Matters
Most firms don't struggle with GIPS compliance because they misunderstand a requirement. They struggle because the knowledge lives in one person's head, the team is stretched thin, or a system issue has been quietly sitting in the queue for months.
Software doesn't fix any of those problems. People do. Having an experienced team involved reduces key-person risk, frees your own staff for higher-value work, and means fewer surprises when verification or a regulatory review comes around.
A Question Worth Asking
If the person who runs your performance work were out for a month, who would pick it up? And if the honest answer is "we'd figure it out" or you simply don’t have an answer, it may be time to think about who else should be in the room.
We're happy to talk through where you are today and what kind of support would actually help. No software demo required. Email us at hello@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.
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.
Most firms that decide to pursue compliance with the Performance Standards (GIPS®) already understand why it matters. They know institutional investors and consultants often expect it. They understand the credibility that comes from standardized, transparent performance reporting. And they recognize that a strong performance reporting process can improve internal consistency well beyond marketing.
What many firms struggle with is not the “why,” but the“how.”
The GIPS standards can be especially intimidating at first glance. There are detailed requirements, technical terminology, and a long list of considerations that touch everything from performance, to operations, compliance, and marketing. For firms approaching GIPS compliance for the first time, it is easy to feel like they need to solve everything at once.
Whether working independently or with external GIPS support,becoming GIPS compliant is significantly more manageable when approachedthrough a structured process.
At a high level, implementing the GIPS standards comes down to four major phases:
- Define the firm and scope the universe of portfolios
- Build policies and procedures
- Construct composites and calculate performance
- Create GIPS Reports and establish ongoing monitoring controls
The order matters more than many firms realize. When the foundation is built correctly at the beginning, the downstream work becomes significantly easier. For a broader overview of what the GIPS standards are and why firms choose to comply, see our earlier post, What Are the GIPS Standards?
Phase 1: Define the Firm and Scope Your Universe
Before constructing composites or calculating returns, firms first need to define the “firm” for the purpose of claiming compliance with the GIPS standards. This sounds simple, but it is often one of the most important decisions in the entire implementation process.
The GIPS standards require compliance on a firm-wide basis. Firms cannot selectively apply compliance to only their best-performing strategies or business lines. The firm definition determines which portfolios fall within the scope of compliance and ultimately impacts composite construction, total firm assets, disclosures, and marketing claims.
For smaller organizations, this step is often straightforward. The legal entity, branding, regulatory registration, and operational structure are usually aligned. In those situations, the firm definition may be relatively easy to document.
For larger organizations with complex legal structures or ones that operate under multiple brands, the analysis can become significantly more complex.
The following questions should be considered:
- How is the firm held out to the public?
- Do affiliates or subsidiaries share investment personnel or investment decision-making?
- How are the various entities registered and branded relative to one another?
- How are investment strategies actually managed across entities?
The answer to these questions matters because the firm definition affects everything that follows. For complex organizations, it is worth investing real time here and involving compliance and legal teams before any other work begins.
Once the firm is defined, the next step is performing a full inventory of assets (or portfolios) that fall within the defined firm. That includes discretionary accounts, non-discretionary accounts, pooled funds, terminated portfolios, and any other assets managed by the firm over the entire period for which the firm will claim compliance.
One of the most common implementation mistakes is discovering late in the process that certain portfolios were overlooked or incorrectly categorized. Taking the time upfront to fully scope the universe of portfolios prevents significant cleanup work later on.
Phase 2: Build Your GIPS Standards Policies & Procedures Manual
The next step is building the firm’s GIPS standards policies and procedures manual, often referred to as the GIPS standards “P&P.”
The GIPS standards require firms to document the policies and procedures used to comply with all applicable requirements. But beyond satisfying the standards themselves, strong documentation creates consistency across operations, compliance, marketing, and portfolio management teams. Your GIPS standards P&P becomes the operational blueprint for how your firm calculates performance and maintains GIPS compliance. When drafted thoughtfully, ongoing maintenance becomes manageable. Firms that rush this phase often find themselves cleaning up problems indefinitely.
A well-designed P&P typically addresses the following:
- Firm definition
- Definition of discretion
- Composite construction rules
- Treatment of significant cash flows and composite minimums
- Calculation methodologies
- Fair valuation hierarchy
- Error correction procedures
- Books and records retention
- GIPS Report distribution policies
- Benchmark selection and changes
- Fee schedules and policies for the use of actual or model fees
The definition of discretion deserves particular attention. Under the GIPS standards, discretion is not the same thing as having legal discretion documented in the investment management agreement. A client may impose restrictions that prevent full implementation of the strategy, and if those restrictions are significant enough, the portfolio should be classified as non-discretionary under the GIPS standards. Firms should establish objective criteria that can be applied consistently across portfolios and clearly document those criteria within their P&P. This determination has a direct impact on composite construction, as only portfolios deemed discretionary maybe included in composites, while non-discretionary portfolios must be excluded.
Calculation methodology should also be clearly addressed within the P&P. Firms should define how external cash flows are handled, the methodology used to asset-weight portfolios within composites, and whether any composites are subject to minimum asset levels or significant cash flow policies. For a more detailed discussion of large cash flow policies versus significant cash flow policies—and why both matter—see our post Large vs. Significant Cash Flows: What’s the Difference? These methodologies should be clearly documented.
Finally, firms often do not devote enough attention to developing their error correction policy during implementation. The GIPS standards require firms to establish materiality thresholds in advance that determine what actions must be taken when an error is identified. The time to think through that process is before an error occurs, not in the middle of responding to one.
We often find that this is the phase where firms realize that implementing GIPS compliance is not just a performance reporting exercise. It frequently exposes inconsistencies in operational workflows, account coding, historical records, or portfolio classifications. That is not necessarily a bad thing. It allows you to intentionally strengthen processes and reporting before those issues surface in higher-stakes situations such as verification, a regulatory examination, or investor due diligence.
One of the biggest hidden benefits of the GIPS compliance implementation process is that it forces firms to formalize processes that may have evolved informally over time. Many firms come out of the GIPS compliance implementation process with cleaner data, stronger internal controls, and more consistency across teams.
The key is to make the policies practical. The best GIPS standards P&Ps are not written purely for regulators or verifiers. They are designed to reflect what the firm actually does in practice and to provide internal teams with a framework they can follow consistently.
Phase 3: Construct Composites and Calculate Performance
Once your policies and procedures are in place, firms can begin the process of constructing composites and calculating performance. This is the phase most firms typically associate with GIPS compliance because it is where the visible performance reporting work happens. At this point, much of the difficult decision-making should already be complete. Composite construction is next and while that may sound straightforward conceptually, this is the phase where most firms get stuck in the implementation process.
Under the GIPS standards, discretionary portfolios must be grouped into composites based on similar investment mandates. The goal is to ensure firms present strategy-level performance fairly and consistently instead of selectively highlighting individual account results. The construction process typically has four steps:
- Identify every portfolio that meets the composite definition
- Determine the correct dates each portfolio should be in and out of the composite
- Asset-weight the portfolio-level monthly returns to produce composite-level performance
- Calculate all required composite-level statistics, including internal dispersion and the three-year annualized ex-post standard deviation of both the composite and the benchmark
It sounds simple, but it’s not always easy. The data work alone is substantial. Before anything meaningful can be built, the underlying portfolio-level data must be reviewed to ensure it is reconciled and accurate. That foundation matters because everything downstream depends on it.
The historical composite membership analysis adds another layer of complexity. Strategies evolve. Clients add or remove restrictions. Portfolios change mandates. When building a composite with a ten-year history, the question is not simply which portfolios belong in the composite today. Itis which portfolios belonged in the composite during each period in the historical record, and why. Working through that analysis portfolio by portfolio and period by period requires both strong documentation and sound judgment.
The good news is that there are tools available to help firms identify historical performance outliers to help test if composite inclusion was accurate. When a portfolio within a composite posts a return that deviates meaningfully from its peers during a given period, that deviation can be identified for further research. Was there a client-imposed restriction during that period that prevented full implementation of the strategy (i.e., making it non-discretionary)? Or was the deviation driven by a large cash flow, different starting position, security-specific activity, or simply the normal variation expected across portfolios managed within the same strategy? The answer determines whether the portfolio appropriately belongs in the composite for that period, and the wrong conclusion in either direction can undermine the integrity of the track record.
It is also important to be direct about the limits of technology in this process. Software can identify anomalies, efficiently perform calculations, and output results once the inputs are correct, but no system makes judgment calls. Determining how composites should be defined, how discretion should be applied, what constitutes a significant restriction, and how to evaluate edge cases in historical membership all require experienced professionals who understand both the investment strategies and the GIPS standards. The policies documented in Phase 2 provide the framework but applying that framework consistently across real portfolios and real historical circumstances requires thoughtful human judgment at every step.
Perhaps most importantly, composite construction should not be treated purely as an operations exercise. If composites are built solely around how data happens to be structured within the portfolio accounting system, without input from the investment team and without alignment with sales and marketing, the result may be operationally convenient but commercially ineffective. Bringing together operations, performance, investment professionals, and sales and marketing teams early in the process is essential. That collaboration is what ultimately produces results that are not only GIPS compliant, but also meaningful, defensible, and aligned with how the firm communicates its investment approach.
Phase 4: Create GIPS Reports and Go Live
The final phase of becoming compliant is creating the GIPS Composite Report(s). The GIPS Report is the firm’s external-facing proof of compliance and is a presentation that must be provided to every prospective client. Getting to this stage is what most people think of as going live, but in practice it is a milestone, not the finish line.
GIPS Reports require more than simply presenting returns in a table. Firms must include required statistics, disclosures, benchmark information, and firm-level details necessary for prospective clients to properly interpret the results. The disclosures are especially important because they provide context investors need to understand how the performance was calculated and what the results represent. They are very specific and must be in sync with what is documented in the P&P and what was performed to construct the composites. For more specifics on what is required, see our previous post, How to Update Your GIPS Reports for the 2020 GIPS Standards.
Once the GIPS Reports are complete and all requirements have been met, the final administrative step to claiming compliance is submitting the GIPS Compliance Notification Form to CFA Institute. This must be filed before compliance can be claimed, and it must be renewed annually.
Ongoing Maintenance: Where Most Firms Struggle
Getting to compliance is an achievement. Staying there requires consistent operational discipline.
The most common breakdowns in ongoing maintenance are rarely dramatic failures. More often, they are small process gaps that compound over time. Portfolios that should have been added to composites were omitted or added late. Significant cash flows were not handled in accordance with the composite’s policy. A new strategy was launched without formally determining whether it warranted the creation of a new composite.
To avoid these breakdowns, firms should incorporate GIPS compliance procedures into their regular monthly or quarterly performance processes rather than treating compliance as an annual reporting exercise. Clear ownership should be assigned internally and firms should establish a recurring compliance calendar that includes monthly composite reviews and annual GIPS Report updates. The GIPS standards policy manual should also be reviewed at least annually to confirm it continues to reflect how the firm actually operates. For a deeper look at what effective ongoing governance looks like in practice, see our post What Good GIPS Compliance Governance Looks Like in Practice.
Should You Get Verified
Verification is not required. Firms that are early in the process sometimes view this as a bigger decision than it needs to be. If a firm chooses to pursue verification, it must be performed by an independent third party, but the decision itself is entirely voluntary.
That said, verification is generally worthwhile, particularly for firms competing for institutional mandates where GIPS compliance is often considered table stakes. According to eVestment, two out of three searches conducted in their database by investors or consultants exclude firms that are not GIPS compliant, so the marketing benefit can be meaningful. Verification also provides an added level of assurance that the firm’s policies and procedures have been designed in accordance with the GIPS standards and implemented consistently across the organization. Operationally, it can create valuable discipline as well, since the expectation of independent review encourages firms to maintain strong processes throughout the year.
For firms that are newer to compliance or navigating budget constraints, the best path is often to first establish a solid compliance foundation and then pursue verification when the timing makes sense. We have also worked alongside nearly every major verifier in the industry and can provide practical insight into how different firms approach the process, what working styles may align best with your organization, and how to evaluate which verifier may be the best fit for your needs. For a more detailed walkthrough of the process, see our series on How to Survive a GIPS Verification.
Final Thoughts
Becoming GIPS compliant can feel overwhelming at the start, especially when going through it for the first time. But it does not have to be. For firms that approach implementation as a structured operational framework — rather than a collection of isolated technical requirements —typically find the process much more manageable.
The goal is not simply to produce a compliant presentation. The real value comes from building a repeatable, transparent, and defensible framework for calculating and presenting investment performance.
When implemented thoughtfully, the GIPS standards do more than support marketing efforts. They help firms improve consistency, strengthen controls, and communicate performance results with greater credibility and transparency. And in an environment where investors continue to demand greater transparency and comparability, those operational improvements can provide a meaningful competitive advantage, strengthening both credibility and investor confidence.
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
Article Topics

How to Update Your GIPS Reports for the 2020 GIPS Standards
Investment firms and asset owners that comply with the GIPS standards are required to make some modifications to their GIPS Reports (formerly known as “GIPS compliant presentations”) to address changes made to the 2020 edition of the Standards. The extent of these updates depends on:
- Whether your organization plans to adopt any new optional policies (e.g., carve-outs, estimated transaction costs, etc.)
- If your organization plans to change any calculation methodologies now allowed under the new standards (e.g., switching from time-weighted returns to money-weighted returns where allowable)
- Whether your organization manages pooled funds, separate accounts, or both.
The change of the report name from compliant presentations to GIPS Reports happened as a result of a reorganization of the standards to address the differences between separate account managers, pooled fund managers and asset owners. Depending on your organization, you could have GIPS Composite Reports, GIPS Pooled Fund Reports, and/or GIPS Asset Owner Reports.
Nevertheless, GIPS Report updates are required for all compliant organizations. The updates involve more than changing the name of the document and can vary significantly based on the organization. In this article we focus only on the changes required for organizations already complying with the 2010 edition of the GIPS standards; however, a complete checklist of Required GIPS Report Disclosures for Firms, covering all disclosures required for firms under the 2020 edition of the GIPS standards is available for download. In addition, a checklist of required disclosures for 2020 GIPS Advertisements is also available for download.
Deadline to Update GIPS Reports
Beyond updating the GIPS Reports for disclosures and statistics, organizations must now be able to update these reports with performance information in a timely fashion. Previously there was no set deadline on when a GIPS Report needed to be updated. Organizations are now required to have their GIPS Reports updated within 12 months after each year end. That means that if your firm presents performance for a standard calendar year, by 31 December 2021 all GIPS compliant organizations are required to have their GIPS Reports updated with 2020 performance statistics and related disclosures.
Many firms prefer to wait until their verification is complete before distributing updated GIPS Reports. This is not required, nor is it recommended, but it can help firms avoid material errors in their performance. Firms that prefer to do this will need to ensure their verification is complete within 12 months after each year end. If your firm needs help making sure this work is completed and your GIPS Reports are updated on time, Longs Peak is available to support your process to get this done.
Minimum Updates Required for GIPS Composite Reports (Formerly Compliant Presentations)
GIPS Composite Reports are the same as what was known as GIPS compliant presentations under 2010 GIPS; however, all firms are required to change the following:
1. Edit the wording for the claim of compliance as it has changed for 2020. This disclosure is required to be word-for-word and the wording depends on whether your firm has been verified and if a performance examination was conducted for the composite. Below is the exact wording firms must use:
For firms that are verified
“[Insert name of FIRM] claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. [Insert name of FIRM] has been independently verified for the periods [Insert dates]. The verification report(s) is/are available upon request.
A firm that claims compliance with the GIPS standards must establish policies and procedures for complying with all the applicable requirements of the GIPS standards. Verification provides assurance on whether the firm’s policies and procedures related to composite and pooled fund maintenance, as well as the calculation, presentation, and distribution of performance, have been designed in compliance with the GIPS standards and have been implemented on a firm-wide basis. Verification does not provide assurance on the accuracy of any specific performance report.”
For composites of a verified firm that have also had a performance examination:
“[Insert name of FIRM] claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. [Insert name of FIRM] has been independently verified for the periods [Insert dates].
A firm that claims compliance with the GIPS standards must establish policies and procedures for complying with all the applicable requirements of the GIPS standards. Verification provides assurance on whether the firm’s policies and procedures related to composite and pooled fund maintenance, as well as the calculation, presentation, and distribution of performance, have been designed in compliance with the GIPS standards and have been implemented on a firm-wide basis. The [insert name of COMPOSITE] has had a performance examination for the periods [insert dates]. The verification and performance examination reports are available upon request.”
For firms that have not been verified:
This did not change in 2020 and should still be disclosded as:
“[Insert name of FIRM] claims compliance with the Global Investment Performance Standards (GIPS®) and has prepared and presented this report in compliance with the GIPS standards. [Insert name of Firm] has not been independently verified.”
2. Add the newly required trademark disclosure, which must be disclosed word-for-word as, “GIPS® is a registered trademark of CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein.”
3. Add the composite’s inception date.
4. If the composite contains a pooled fund and the firm elects to present prospective pooled fund investors with the GIPS Composite Report rather than a GIPS Pooled Fund Report (discussed later), the fee schedule disclosed must be that of the pooled fund and is required to include the total pooled fund expense ratio.
5. If the firm manages limited distribution pooled funds, the firm must disclose the availability of a list of descriptions of their limited distribution pooled funds. If the firm manages broad distribution pooled funds, the firm must disclose the availability of a list of the names of the broad distribution pooled funds the firm manages.
6. Edit the disclosure previously required about policies for valuing portfolios, calculating performance, and preparing compliant presentations to refer to valuing “investments” instead of valuing “portfolios” and preparing “GIPS Reports” instead of “compliant presentations.” Specifically, that disclosure should now state (emphasis added for clarity), “Policies for valuing investments, calculating performance, and preparing GIPS Reports are available upon request.”
7. If a custom benchmark is used, such as a blended benchmark, the benchmark must clearly be labeled and disclosed as a “custom benchmark.”
8. If not already clearly disclosed, firms are required to indicate whether 3-year annualized ex post standard deviation and dispersion were calculated using gross-of-fee returns or net-of-fee returns. If other risk measures are presented, this must be disclosed for all risk measures.
2020 GIPS Report Changes for Firms with Pooled Funds
Under the 2010 GIPS standards, firms were required to provide GIPS compliant presentations to all prospective clients, as defined in the firm’s GIPS policies and procedures. While not perfectly clear, many firms interpreted this to mean all prospective separate account investors that were interested in opening a separate account that would be eligible for composite inclusion.
The 2020 edition of the GIPS standards clarifies how GIPS applies when marketing to prospective pooled fund investors. Firms are not required to provide GIPS Reports to prospective investors in “Broad Distribution Pooled Funds,” such as mutual funds, but firms are required to provide GIPS Reports to prospective investors in “Limited Distribution Pooled Funds,” such as private funds set up as limited partnerships.
Prospective investors in a limited distribution pooled fund must be provided with one of the following:
- GIPS Composite Report – This is for the composite in which the pooled fund is included. As mentioned in item 4 above, the fee disclosures must be modified to describe the fees of the fund rather than just the management fee that would normally be presented for separate account prospects of the composite. In the GIPS Composite Report, firms can either include both the management fee information for separate account prospects and the fund fee information for pooled fund prospects or two separate versions of the GIPS Composite Report can be maintained, 1) for use with separate account prospects describing the applicable management fees and 2) for pooled fund prospects describing the total fund expenses.
- GIPS Pooled Fund Report – When marketing to pooled fund prospective investors, a new alternative to using a GIPS Composite Report is to create a GIPS Pooled Fund Report. This report is very similar to a GIPS Composite Report, but it describes the details of the actual fund instead of more broadly describing the strategy as done previously in a GIPS Composite Report. All disclosures and statistics are the same as a GIPS Composite Report, except for the following modifications:
- Returns are for the fund itself rather than for a composite of similarly managed portfolios.
- If net-of-fee returns are presented they must be net of total pooled fund fees, not only transaction costs and management fees.
- Dispersion and number of portfolios is not presented since the results are for a single fund.
- The pooled fund description differs from a composite description in that it discusses the actual investment vehicle. Composite descriptions broadly describe the investment objectives and key risks of the strategy without referencing any specific portfolio.
2020 GIPS Report Utilizing Money-Weighted Returns
The 2010 edition of the GIPS standards only allowed the use of money-weighted returns in private equity composites and certain real estate composites where the portfolio manager controlled the timing and amount of external cash flows. The 2020 edition of the GIPS standards allows money-weighted returns to be used, regardless of the asset class as long as certain criteria is met. Please see Longs Peak’s article on How to Update your GIPS Policies & Procedures for GIPS 2020 for more information on when using a money-weighted return is acceptable.
When money-weighted returns are utilized, the requirements for statistics and disclosures are very similar to what was previously required for private equity. For example, instead of time-weighted returns, the GIPS Report will include money-weighted returns as well as several statistics and multiples including:
- Cumulative committed capital
- Since-inception paid-in capital
- Since-inception distributions
- Total value to since-inception paid-in capital
- Since-inception distributions to since-inception paid-in capital
- Since-inception paid-in capital to cumulative committed capital
- Residual value to since-inception paid-in capital
Two differences from what was required for private equity composites under the 2010 GIPS standards and what is required in money-weighted GIPS Reports under the 2020 GIPS standards include:
- Periods presented for statistics – Under the 2010 GIPS standards, private equity composites were required to present returns and other statistics/multiples as of each year-end (e.g., since inception money-weighted returns were presented from inception through the end of each calendar year). The 2020 GIPS standards only require the returns and other figures to be presented through the latest period end (e.g., since inception money-weighted returns are only required to be presented from inception through the end of the most recent period).
- Subscription line of credit – When a subscription line of credit is used, the money-weighted return must be presented both with and without the subscription line of credit unless:
- The principal was repaid within 120 days using called capital and
- No principal from the line of credit was used to fund distributions.
If these two criteria are met, then the money-weighted return may be presented in the GIPS Report without the subscription line of credit.
In cases where firms must present money-weighted returns both with and without the subscription line of credit, firms must disclose:
- The purpose for using the subscription line of credit.
- The size of the subscription line of credit as of the end of the most recent annual period.
- The amount outstanding on the subscription line of credit as of the end of the most recent annual period.
Additionally, if your firm was not using daily cash flows prior to 1 January 2020, you must disclose the frequency that was used (e.g., monthly or quarterly). Daily cash flows are required for periods beginning 1 January 2020.
2020 GIPS Report Changes for Asset Owners
Asset Owners are required to report time-weighted returns for each total fund. In addition to reporting the time weighted returns for each individual total fund, asset owners have the option of creating composites. Composites can be created to present asset class performance or an aggregation of multiple total funds with similar mandates. For these optional composites, asset owners may present time-weighted returns, money-weighted returns, or both.
GIPS Asset Owner Reports for total funds are very similar to the GIPS Pooled Fund Reports created by firms with the following modifications:
- Net-of-fee returns must be included and must be net of:
- transaction costs,
- all fees and expenses (for externally managed pooled funds),
- investment management fees (for externally managed segregated accounts), and
- investment management costs.
Unlike firms that charge a management fee, investment management costs for asset owners include all costs involved in managing the assets including general overhead costs of the investment management function of the asset owner.
2020 GIPS Report Changes for other Optional Policies
As discussed in Longs Peak’s article on How to Update your GIPS Policies & Procedures for GIPS 2020, the updated standards introduce some optional policies firms may elect to adopt. If the following are utilized, disclosures must be updated as described.
Carve-outs – If a composite includes carve-outs with allocated cash, the composite must include “carve-out” in the composite name. This carve-out composite must disclose that the composite includes carve-outs with allocated cash along with a description of how the cash is allocated and the percentage of the composite comprised of carve-outs as of each year end. If the firm also has a composite of standalone portfolios following the same strategy, the annual performance and annual assets of the standalone composite must also be presented with the carve-out composite and a disclosure must be included explaining that the GIPS Report for the composite of standalone portfolios is available upon request.
Estimated Transaction Costs – Historically, only actual transaction costs could be used to reduce returns. Because of this, wrap or other bundled fee accounts (where transaction costs could not be clearly identified) were unable to present a gross-of-fee return. Instead, a pure gross-of-fee return was generally presented, which needed to be labelled as supplemental information. The 2020 GIPS standards now allow the use of estimated transaction costs in cases where actual transaction costs cannot be identified. If estimated transaction costs are used, firms must disclose how the estimated transaction costs are determined.
Model Management Fees – The ability to use model investment management fees to calculate net-of-fee returns is not new, but there is a new disclosure requirement to describe the methodology used to determine the net-of-fee returns using the model fee. Also, under the 2010 edition of the GIPS standards firms were required to disclose the percentage of the composite comprised of non-fee-paying portfolios. Under the 2020 GIPS standards this is still required for composites that present net-of-fee returns using actual fees but is no longer required for composites utilizing model fees to calculate net-of-fee returns.
Advisory-Only Assets – As more firms move strategies to UMA platforms and other similar arrangements where one firm provides trades for another firm to implement, the 2020 GIPS standards now provide guidance on how these assets may be reported. Historically, most firms excluded these assets when reporting total firm assets, but the guidance was not clear so some firms were including these assets in their total firm assets. The 2020 GIPS standards now clearly state that these assets must be excluded from total firm assets, but they do provide guidance on how these assets can also be reported for firms that choose to do so.
In addition to the official total firm assets that excludes advisory-only assets, firms can choose to also present advisory-only assets or a combination of total firm assets and advisory-only assets. Either option must be clearly labelled to explain what is presented. The same can be done for composite assets. Firms must present the actual composite assets and then may also present the advisory-only assets following the strategy or a combination of the composite assets and advisory-only assets together.
Uncalled Committed Capital – Similar to advisory-only assets described above, private fund managers with committed capital cannot include uncalled committed capital when reporting pooled fund assets and total firm assets. Only the current fair value of the fund or firm’s assets can be presented as the fund or total firm assets. But many firms wish to present the amount of uncalled committed capital they have subscribed to their funds.
The 2020 GIPS standards now provide clear guidance on how uncalled committed capital can be shown. At the pooled fund level, it can be combined with the pooled fund assets or it can be shown separately. At the total firm level, it also can be combined with total firm assets or shown separately. Whichever option is chosen, it must be clearly labelled to explain what it represents. To be clear, the official total firm or pooled fund assets must still be disclosed excluding uncalled committed capital. These options to present uncalled committed capital are only allowed in addition to, not instead of this required statistic.
Disclosure Sunset Provisions – Historically, there was no guidance that allowed firms to remove disclosures. The 2020 GIPS standards now specify certain disclosures that can be removed after one year as long as the firm feels the disclosures are no longer necessary for a user of the report to be able to interpret the information presented. Examples of what may now be removed after one year include disclosures regarding:
- Significant events
- Composite name changes
- Retroactive benchmark changes
- Material errors
- Changes in return type (e.g., change from reporting TWR to MWR)
Questions?
If you have a situation that we didn’t cover here that is specific to your firm or for more information on GIPS Reports, the changes to the GIPS standards for 2020, or GIPS compliance in general, contact Matt Deatherage at matt@longspeakadvisory.com or Sean Gilligan at sean@longspeakadvisory.com.

What is the Sortino Ratio?
The Sortino Ratio is similar to the Sharpe Ratio as it is used to compare and rank managers with similar strategies. However, unlike Sharpe, the Sortino Ratio measures the incremental average strategy return over a minimum acceptable return per unit of downside risk rather than total risk.
Because of this difference, the Sortino Ratio may be more appropriate than the Sharpe Ratio when assessing strategies with non-normal return streams. For example, the Sharpe Ratio is appropriate when assessing a traditional equity manager, while the Sortino Ratio would be more appropriate for a hedge fund strategy that uses derivatives to seek asymmetrical, positive spikes in performance. The Sharpe Ratio, using total risk (measured by standard deviation), would penalize this hedge fund manager for these positive spikes in performance, while the Sortino Ratio, using downside risk (measured by downside deviation), would not.
Sortino Ratio Formula

Annualized Sortino Ratio
When calculating the Sortino Ratio using monthly data, the Sortino Ratio is annualized by multiplying the entire result by the square root of 12.
What is a Good Sortino Ratio?
The Sortino Ratio is a ranking device so a portfolio’s Sortino Ratio should be compared to that of other portfolios rather than evaluated independently. In general, investors prefer higher Sortino Ratios when comparing similarly managed portfolios.
Sortino Ratio vs. Sharpe Ratio Calculation Example
Suppose two similar strategies, Strategy A and Strategy B, had the following characteristics over one year. For this period, the minimum acceptable return is the risk-free rate, which is 0.10% (monthly average return).

Please note that the Sortino Ratio calculated in this example is based on monthly data and, therefore, must be annualized to get the final result. The following is a breakdown of the calculation:

For more details on how to calculate the Sharpe Ratio, check out What is the Sharpe Ratio.
Although the strategies have the same average monthly return over the one-year period, the Sortino Ratios differ significantly due to their differences in downside risk (i.e., downside deviation). Strategy A is preferred over Strategy B to an investor deciding between the two because it has a higher Sortino Ratio.
When using the Sharpe Ratio to evaluate the two strategies, the result is the opposite than it is when using the Sortino Ratio. How can this be?
If the Standard Deviation (i.e., total risk) is higher for Strategy A than Strategy B, but Downside Deviation (i.e., downside risk) is lower for Strategy A than Strategy B, we can infer that at least some of the volatility in Strategy A’s return stream is caused by positive spikes in performance. Standard Deviation treats all volatility (both positive and negative) equally, while Downside Deviation does not penalize the manager for positive volatility.
Sortino Ratio Interpretation
The Sortino Ratio is one of the best measures for return streams with non-normal distributions (such as hedge funds). This is because Sortino only penalizes for negative volatility and not positive spikes in performance.
If, for example, an investor is looking for a high reward strategy, then upside volatility can be a good thing.
Why is the Sortino Ratio Important?
The Sortino Ratio allows investors to evaluate portfolio performance for non-normal return distributions after adjusting for risk. Comparing returns without accounting for risk does not provide a complete picture of the strategy. Using total risk, as the Sharpe Ratio does, can make a strategy look riskier than it truly is if the volatility is skewed positively.
Sortino Ratio Calculation: Using Arithmetic Mean or Geometric Mean
Because the Sortino Ratio compares return to risk (through downside deviation), we use Arithmetic Mean to calculate the strategy return. Geometric Mean penalizes the return stream for taking on more risk. However, since the Sortino Ratio already accounts for risk in the denominator, using Geometric Mean in the numerator would account for risk twice.

How to Update your GIPS Policies & Procedures for GIPS 2020
If you are an investment firm or asset owner that complies with the GIPS standards you are required to make some modifications to yourGIPS policies and procedures (“P&P”) to address changes made to the 2020edition of the Standards. The extent of these updates depends on:
- whether your organization plans to adopt any new optional policies,
- whether you have pooled funds to add to the current list of composites, or
- if your organization plans to change any calculation methodologies now allowed under the new standards.
Like other GIPS requirements, consistent application and adequate documentation are critical to ensuring these updates and changes are applied correctly and consistently.
GIPS 2020: Minimum Requirements for all GIPSCompliant Organizations
There are some required GIPS policies & procedure updates that will impact all organizations claiming compliance. At a minimum, all firms and asset owners must address the following in their P&P:
Terminology
What was previously called “Compliant Presentations” are now called “GIPS Reports” in the 2020 GIPS standards. Likely, the term “CompliantPresentations” is used throughout your P&P, which needs to be replaced with“GIPS Reports” to be in sync with the language of the updated standards.
Demonstrate that GIPS Reports are Distributed
It has always been a good idea to maintain a log documenting the distribution of GIPS Reports to help support that your firm met the requirement of providing them to prospective clients; however, it was not previously required. The 2020 edition of the GIPS standards now requires firms to demonstrate how it made every reasonable effort to provide a GIPS Report to prospective clients that are required to receive one.
The most common way to do this is by maintaining a log of the distribution in a spreadsheet or by noting the distribution in your firm’s CRM system. If noting distribution in your CRM, it is important to populate this in a way that can easily be extracted into a report. Your GIPS verifier is now required to test this so you will need to be able to produce a report demonstrating that your firm is distributing GIPS Reports to prospective clients.
In addition, you must now update your P&P to document the process for how this is maintained. Although each firm will need to document this differently to accurately describe their process (i.e., the system in which it is maintained and who is responsible for maintaining it), below is an example of how this may be documented:
Each time a GIPS Report is distributed, the firm’s SalesAssociate is responsible for logging the distribution on the firm’s CRM system.This documentation will include who received the GIPS Report, the version of the GIPS Report they received, the method of delivery, and the date it was delivered. This information may be extracted from the CRM system by the SalesAssociate if requested by a verifier, regulator, or if needed internally.
Error Correction Procedures
In the 2010 edition of the GIPS standards, if a material error was discovered in a compliant presentation, correction and redistribution was required with a disclosure of the change to “all prospective clients and other parties that received the erroneous compliant presentation.” In addition to these, the 2020 GIPS standards specifically call out providing corrected GIPSReports to your current GIPS verifier as well as any former verifier or current client that received the GIPS Report containing the material error.
Currently, most firms’ policies relating to material errors are likely limited to the action they take to redistribute to current prospective clients. We recommend updating this language to specifically address the need to provide the corrected presentation to verifiers and clients who received the erroneous presentation as well. An example of how this may be documented is provided below:
Our firm will determine an identified error is material if the error exceeds the materiality thresholds stated in the Error Correction Policy: Materiality Grid. If this occurs, we will correct all affected GIPS Reports, include a disclosure of the change, and make every reasonable effort to provide a corrected GIPS Report to:
- Prospective clients that received the GIPS Report t hat had the material error;
- Clients and any former verifiers that received theGIPS Report that had the material error; and
- Current GIPS verifier.
Verifier Independence
Verifiers are prohibited from testing their own work and, therefore, cannot help their clients by writing policies, calculating performance, creating GIPS Reports, etc. To help ensure this independence is maintained, firms that are verified are now required to gain an understanding of their verifier’s policies for maintaining independence and to consider their verifier’s assessment of independence to ensure there are no conflicts.
To comply with this, firms must request that their verifier provide documentation describing the measures they take during the verification process to ensure independence is maintained. The procedures for requesting and assessing this needs to be described in the firm’s GIPS policies &procedures. Below is an example of what this might look like:
Our firm has engaged XYZ Verification Firm as an independent third-party verification firm to verify our claim of compliance. Each year, prior to the start of the annual verification, we request the independence policy statement from the verification firm. If there are no changes from the prior year, this confirmation is requested in writing. Any potential threats to independence, either in fact or in appearance, are discussed with the verifier to resolve immediately.
GIPS Report Updates
We will discuss all the changes relating to GIPS Reports in a separate blog; however, some of those changes will require updates to your firm’s GIPS policies and procedures, which we do want to discuss here.Presenting annual internal dispersion and three-year annualized ex post standard deviation is not new; however, it is new that firms are required to disclose whether gross-of-fee or net-of-fee returns are used in these calculations. We recommend adding language to your P&P that makes it clear whether you will use gross-of-fee or net-of-fee returns. Including this in yourP&P will help you ensure the calculation is consistent with the disclosure you will be adding to your GIPS Reports. An example of how this could be worded is as follows:
Composite internal dispersion is measured using the asset-weighted standard deviation of annual gross-of-fee returns of those portfolios included in the composite for the full year. The three-year annualized ex post standard deviation measures the variability of the composite gross-of-fee returns and benchmark returns over the preceding 36-month period.
While either gross-of-fee or net-of-fee returns are acceptable, at Longs Peak we generally recommend that our clients use gross-of-fee returns so the presented volatility relates specifically to the implementation of the strategy and is not affected by management fees (which may differ by account, be paid at different times, etc).
Additionally, there is a new requirement to update GIPSReports with the prior year’s information within 12 months of the period ending. In other words, statistics for the period ending December 31, 2020 must be added to your GIPS Reports by December 31, 2021.That will be plenty of time for most firms, but to ensure this is done, we recommend adding a procedure to your P&P document simply explaining that the reports must be updated within12 months after the end of each annual period.
GIPS 2020: Changes for Firms with Pooled Funds
Firms that have pooled funds will have a few additional changes to make to their GIPS policies & procedures.
Terminology
Most firms will have language in their P&P referring to “prospective clients.” In the 2020 GIPS standards, the term prospective client refers specifically to a prospective separate account investor while the term “prospective investor” is used when referring to a prospective pooled fund investor. Firms need to review their P&P language and make updates to define both terms and ensure they are using the appropriate term depending on the context of what is being described.
List of Pooled Funds
Firms have always been required to maintain a list of composite descriptions, but now the same is needed for each pooled fund the firm manages. For each limited distribution pooled fund, a description needs to be included (similar to what was done historically for composites). Broad distribution pooled funds need to be listed, but no description is required.
If you are unsure whether a pooled fund is considered broad distribution or limited, broad distribution pooled funds are defined in the glossary of the 2020 GIPS standards as “A pooled fund that is regulated under a framework that would permit the general public to purchase or hold the pooled fund’s shares and is not exclusively offered in one-on-one presentations.Limited distribution pooled funds are simply defined as any pooled fund that does not meet the definition of a broad distribution pooled fund.
Pooled Fund Inception Date
Pooled fund performance must be reported back to the pooled fund’s inception date. How the inception date was determined must be documented in the firm’s GIPS policies & procedures. Inception date could be based on when investment management fees are first charged, when the first investment-related cash flow takes place, when the first capital call is made, or when committed capital is closed and legally binding. Whatever criteria is used to determine the inception date must be clearly described in the P&P to ensure an appropriate inception date is used for each pooled fund managed by the firm.
Error Correction Thresholds
If language used to document error correction materiality thresholds is specific to composites, this will need to be modified to incorporate thresholds for statistics reported in GIPS Pooled Fund Reports as well. If the same thresholds are appropriate for both composites and pooled funds (e.g. composite and pooled fund performance can have the same threshold and composite and pooled fund assets can have the same threshold) then this maybe as simple as changing “Composite” to “Composite/Pooled Fund” throughout this section.
Additionally, if your firm is now presenting money-weighted returns and other related multiples for closed-end funds, you will need to add thresholds to your policy for these statistics as well.
Changes for other Optional Policies
The 2020 GIPS standards offer some more flexibility to ensure theyare as meaningful and useful as possible to all types of investment firms and asset owners. If any of these policies are utilized, additional changes will berequired to describe their use in your firm’s GIPS policies & procedures.Examples of these optional policies include, but are not limited to:
Carve-Outs
If a firm decides to utilize carve-outs with allocated cash, the new carve-out composite will need to be documented in the current list of composites. In addition, the firm will need to implement policies and procedures as to how they allocate cash, how they identify appropriate asset buckets to carve-out from existing accounts, which accounts have asset groups that need to be carved-out to meet the new composite definition, and document other composite related policies applied to the carve-out composite.
Portability
Historically, GIPS compliant firms meeting the portability requirements were required to link the historical performance record to the ongoing performance. The 2020 GIPS standards change this to make linking optional. When portable track records exist, firms need to document in theirP&P 1) whether the historical track record meets the GIPS portability requirements and 2) whether they are electing to link the historical performance record or choosing to not link it.
Estimated Transaction Costs
The GIPS standards define “gross-of-fees” as the return on investments reduced by transaction costs. Historically, firms complying with the GIPS standards were prohibited from estimating transaction costs; the use of actual transaction costs was required. The 2020 GIPS standards now allow estimated transaction costs to be used in cases where actual transaction costs are not known.
Using actual transaction costs is straightforward for traditional portfolios that pay transaction costs in the form of commissions oneach trade. The issue most commonly arises with wrap accounts that pay transaction costs as part of a bundled fee.
Historically, firms were not able to present returns gross-of-fees for their composites containing wrap accounts because they wereunable to determine the actual transaction costs. Most firms instead present“pure gross” returns, which are gross of the entire wrap fee and are requiredto be labelled as supplemental information.
Allowing estimated transaction costs will give firms managing wrap accounts the option to estimate the portion of the wrap fee that is for transaction costs and reduce returns by this estimated figure.
If estimated transaction costs are utilized, the firm must disclose in their GIPS Reports how these estimated transaction costs aredetermined. Similarly, the process used to determine the estimated transaction costs and the methodology utilized to reduce the returns by the estimated transaction costs needs to be documented in the firm’s P&P.
Model Management Fees
Previously, GIPS compliant firms using model investment management fees (rather than actual fees) to determine net-of-fee results were required to use the highest investment management fee. This was generally interpreted as the highest fee from the composite’s fee schedule or the highest fee-paying portfolio in the composite, whichever was higher. In the 2020 GIPS standards, firms using model management fees are required to use a fee that is“appropriate” to the prospective client. While the model fee doesn’t specifically have to be the highest fee, the resulting returns still need to be equal to or lower than the results that would be calculated if actual management fees were used.
If your P&P already describes using the highest management fee and you will continue to use the highest fee then no change is needed. If you will implement a new process other than highest fee, then it is important to update your P&P to describe how the model fee will be determined and applied. This description needs to include how you will confirm that the net-of-fee returns using the model fee are not higher than they would be if the actual investment management fees were used.
Presenting Advisory-Only Assets
Firms that have Unified Managed Accounts (“UMA Accounts”) or other similar arrangements where they are simply providing a model to be implemented by another party generally are not able to include these accounts in their total firm assets. These accounts are considered “advisory-only” because the manager is only providing the model and has no responsibility to implement the strategy or monitor the portfolios on an ongoing basis.
This type of arrangement has become increasingly popular over the last decade. Given the popularity of these relationships, many firms now have a large amount of advisory-only assets that they would like to report.Because of this demand, the 2020 GIPS standards have provided guidance outlining the proper way for firms to present these assets separate from their total firm assets. Firms electing to present these assets must make it clear how they intend to report them in their GIPS Reports.
Historically, many firms documented in their P&P something like, “all accounts deemed to be advisory-only, hypothetical, or model in nature are excluded from total firm assets” to make it clear that they were not including anything in total firm assets that was prohibited. Firms now electing to separately present advisory-only assets must add an additional statement describing how they will be presented. For example, “Some of the firm’sstrategies are offered through UMA platforms on an advisory-only basis. Thes assets are presented separately from the firm’s composite assets and total firmassets and will be labelled ‘Advisory-Only Assets’.”
Presenting Money-Weighted Returns
Historically, time-weighted returns were required with two specific asset class exceptions: Private Equity and Real Estate (when RealEstate was managed in a Private Equity-like fund). The 2020 GIPS standards have now removed the asset-class specific requirements. Instead, firms may now present money-weighted returns for any asset class as long as the firm has control over the external cash flows and the composite or pooled fund has at least one of the following characteristics:
- Closed-end
- Fixed life
- Fixed commitment
- Illiquid investments are significant portion of strategy.
For firms meeting this criteria and electing to present money-weighted returns, the P&P must be updated to 1) note that the criteria was met, 2)indicate the election to present money-weighted returns, and 3) outline the methodology utilized to calculate the money-weighted return and other related multiples that must be presented in conjunction with the money-weighted return.
Other Considerations for GIPS Policies &Procedures
When going through your firm’s GIPS policies & procedures to make the required changes for the 2020 GIPS standards, this is a great opportunity to review the document as a whole to ensure everything is still relevant, applicable and accurate. One of the most common deficiencies regulators write in examinations is that policy and procedure documents do not reflect actual practices of the firm. We recommend a comprehensive review be conducted annually. Check out GIPS Compliance Actions for the New Year for a step-by-step guide to this review .
Questions?
If you have a situation that we didn’t cover here that is specific to your firm or for more information on GIPS Policies and Procedures, the changes to the GIPS standards for 2020, or GIPS compliance in general, reach out to us today (or contact Matt Deatherage at matt@longspeakadvisory.com or Sean Gilligan at sean@longspeakadvisory.com).

How to Comply with the 2020 GIPS Standards
A new decade is upon us and with the new decade comes a series of new requirements in terms of investment performance reporting for firms and asset owners that elect to claim compliance with the GIPS standards.
Many organizations have elected to adopt the 2020 edition of the GIPS standards early and have already put a solid foundation in place for the updated requirements; however, many organizations have not. The adoption deadline for all compliant organizations is rapidly approaching, so if your organization has not begun this conversion, now is the time to get started.
What is Changing and Why
It has been over a decade since the last edition of the GIPS standards was released, and quite frankly, the industry has changed since 2010. As the industry has evolved, CFA Institute has released a number of Q&A’s, guidance statements, and interpretations on how the changes in the industry impact the standards.
Ten years of updates have resulted in a vast repository of information needed to obtain the guidance required to comply. Having so many different resources for guidance (the 2010 GIPS Handbook, separate guidance statements, the Q&A database, and the GIPS Help Desk) has made managing the requirements of GIPS a pretty daunting task; thus, one of the goals of the 2020 standards is to centralize all of the updates that have come out over the past ten years. The 2020 GIPS standards consolidates many of the concepts previously addressed in guidance statements and Q&A’s, allowing the new provisions and explanation of the provisions to serve as the primary source that firms, asset owners, verifiers, and consultants can look to for guidance.
Additionally, the 2010 standards were heavily focused on composites and the traditional definition of prospective clients. Using this as the main framework is not always applicable to organizations that primarily manage pooled funds or asset owners that do not compete for business or report performance to prospective clients. To address this, CFA Institute set out to make this new edition of the standards more applicable to pooled fund managers and asset owners. These updates were designed to make claiming compliance easier and more relevant for these types of managers, while not creating additional burdens on organizations that are already compliant with GIPS. This goal is evident in the new format of the provisions, which separately focuses on requirements for investment firms, asset owners, and verifiers.
In addition to the separation of pooled funds and composites, the guidance is broader on when organizations may present money-weighted returns instead of time-weighted returns. This change now allows the decision to be based on the investment vehicle structure and who controls the timing and amount of external cash flows, rather than limiting money-weighted returns to certain asset classes. This is a welcomed update in the industry as many organizations were frustrated by requirements to calculate and present time-weighted returns when this type of return was not the most meaningful representation of how they managed their investment strategies.
How the 2020 GIPS Standards are Organized
For ease of use and navigation, the 2020 GIPS standards is broken out into three different groups of tailored provisions – firms, asset owners, and verifiers. Each containing specific requirements and recommendations applicable for that type of organization.
As an organization claiming compliance or working to become compliant for the first time, you will need to determine whether the set of requirements for firms or assets owners is applicable to your claim of compliance. The primary distinguishing factor is whether your organization competes for business and manages external money, or reports to an oversight board and manages internal money. The answer to this determines which set of tailored provisions should be followed and sets the framework for how the standards will apply.
Where to Start – GIPS Compliance Updates
Regardless of whether you are excited for the updates to the standards, they are coming and will be required for all firms and asset owners claiming compliance with GIPS. The new requirements take effect once your GIPS Reports (formerly called Compliant Presentations) present performance information that is inclusive of the period 31 December 2020.
There is a lot of information available and dissecting everything that has been released can be overwhelming. For organizations that have never claimed compliance, the good news is that the new standards are more applicable and easier to adopt than they were previously.
For most organizations currently claiming compliance, what’s great is that the new standards do not require a lot of changes, rather they mostly provide optional procedures that you may choose to adopt if you find it beneficial to do so. However, some firms will require more work.
At Longs Peak, we have created the following questionnaire designed to help you determine if converting to the 2020 GIPS standards will require more than a few minor tweaks. This list does not include all changes, but includes the top ten material changes that may require a project plan to implement the required changes by the effective date of the 2020 GIPS standards.
Answering “Yes” to any of the following questions means your organization may require more than a few quick tweaks to implement the 2020 changes:
GIPS 2020 Checklist
- Does your firm have limited distribution pooled funds (i.e., private funds that are not regulated under a framework that would permit the general public to purchase shares in the fund without a one-on-one presentation)?
- Has your firm created single account composites for pooled funds solely for the purpose of meeting the GIPS requirement of having every discretionary, fee-paying portfolio in at least one composite?
- Does your firm have multi-strategy portfolios (e.g., balanced portfolios where the equity and fixed income segments each could be represented as standalone strategies) where you would like to carve-out the individual strategies into their own composites?
- Does your firm have portfolios where actual transaction costs are unavailable (e.g., wrap accounts or other bundled fee arrangements) and you would like to estimate transaction costs to show gross-of-fee returns without labeling the returns as supplemental information?
- Does your firm have portfolios where your firm controls the amount and timing of external cash flows (other than for private equity or real estate) and you would like to present money-weighted returns rather than time-weighted returns?
- Does your firm have real estate or private equity composites?
- Does your firm include theoretical performance (e.g., model performance) as part of a GIPS report?
- Does your firm follow the Advertising Guidelines to claim compliance with the GIPS standards outside of your GIPS Reports?
- Does your firm currently update your GIPS compliant presentations more than 12 months after the year ends?
- Does your firm have advisory-only assets or uncalled committed capital you wish to present in your GIPS Report?
Although the intent is for the adoption of the standards to be more relevant, many organizations find themselves asking “where do I even begin?” The great news is that you don’t have to figure this all out on your own.
At Longs Peak, we have spent countless hours familiarizing ourselves with the new standards and have helped all of our clients begin to adopt the changes. We know what issues come up and how to navigate the changes required.
As a consultant, we do not have independence requirements like your verifier, so we can actually help you implement many of the 2020 changes required for your organization. If you do not already work with a GIPS consultant, now may be a good time to consider hiring one, especially if you lack the resources needed to get this done by the deadline to convert to the 2020 GIPS standards.
Contact us if you do not wish to read through all of the requirements and recommendations to identify what actions are required for your organization.
Finally, if you would like to read more about what changed and why, we have summarized the main changes to the GIPS standards in GIPS 2020 What’s Changing and What you Should Do.

The recent market volatility probably has you wondering how your strategy has fared through this unprecedented time. Disruptive market environments tend to reveal critical information about active managers that help investors see those that truly add value, and those that don’t. So, what should you do to evaluate your actively-managed strategy and how can you help your clients and prospects understand how your strategy performed during these difficult times? Read on.
Investment Performance in Up-Markets vs Down-Markets
During the long bull market run over the last 10+ years, investment firms have been able to effectively market their actively managed investment strategies with an emphasis on pure performance with little, if any, focus on risk. Consistent outperformance in up-markets is great, but it does not demonstrate how the strategy will react to a market downturn. Risk always goes hand-in-hand with performance and is increasingly important to discuss with clients and prospective clients as we navigate the highly volatile downturn we are currently experiencing.
Statistics used to present the results of actively managed strategies should do more than simply show the returns of the strategy vs. the returns of the benchmark. While returns show us where the strategy and benchmark ended and how much they changed over a stated period of time, they do not show how bumpy the road was to get there.
Investment performance and risk statistics should be used to help tell the story of how your firm actively manages the presented strategy. If your strategy description says that it will outperform in up-markets and provide protection on the downside, you should be presenting performance appraisal measures and risk statistics, such as Jensen’s Alpha, Sharpe ratio, Treynor ratio, up and down-market capture ratios, etc. that back-up those claims.
Types of Investment Risk
When assessing investment risk there are two main risk indicators to look at 1) systematic risk (i.e., market risk) and 2) total risk, which includes both systematic risk and unsystematic risk (i.e., security specific risk).
Systematic Risk Statistics
The most common way to assess the systematic risk of a strategy compared to its benchmark is by looking at the strategy’s beta. Beta measures the sensitivity of a strategy to market movements. If the strategy returns move perfectly in sync with the benchmark return then the strategy’s beta as compared to that benchmark is 1 (i.e., they are perfectly correlated).
If every time the benchmark goes up 1% the strategy goes up 1.2% and every time the benchmark goes down 1% the strategy goes down 1.2% then the beta is 1.2. This means that the portfolio has increased its systematic risk (perhaps through adding leverage, but otherwise replicated the index). In this case, the portfolio manager has increased the strategy’s systematic risk and volatility as compared to the benchmark, but the manager has not added alpha. This strategy will outperform on the upside and underperform on the downside.
To determine if the portfolio manager has “added alpha,” you can calculate Jensen’s alpha for the strategy. Jensen’s alpha measures how much the strategy outperformed its expected return, with the expected return determined based on the risk-free rate plus the beta-adjusted benchmark return. If the portfolio manager is truly “adding alpha” (through stock selection, over/underweighting sectors, etc.) and not just increasing systematic risk in their active management, then the strategy’s Jensen’s alpha should be positive.
Demonstrating positive alpha over a sustained period of time demonstrates to clients and prospects of the strategy that the active decisions made by the portfolio manager resulted in an increased return without increasing systematic risk.
Total Risk Statistics
Total risk is generally measured with standard deviation. Standard deviation has become more commonly presented, especially since the 3-year annualized ex-post standard deviation became required for GIPS Reports; however, this information may not be easily understood by readers of a performance report without some explanation.
If your investment strategy has returns that outperformed the benchmark AND has a standard deviation that is lower than the benchmark’s standard deviation, you can emphasize to your clients and prospects that you have outperformed the benchmark while taking less risk to do so (i.e., you had a less bumpy ride than the benchmark to get to your end result).
If your strategy’s returns did not outperform the benchmark, but your standard deviation is lower than that of the benchmark, you still may have outperformed the benchmark when looked at on a risk-adjusted basis. The most common way to assess this is with the Sharpe ratio.
The Sharpe ratio is one of the most popular performance appraisal measures. It measures excess return per unit of total risk. You can easily calculate this by taking your strategy’s average return minus the average risk-free rate and dividing that by the strategy’s standard deviation.
The Sharpe ratio is a ranking device, so the strategy’s Sharpe ratio on its own does not mean much. You should complete the same calculation for the benchmark and compare the two. If your strategy’s Sharpe ratio is higher than the Sharpe ratio of the benchmark then you can explain to your clients and prospects that you outperformed the benchmark on a risk-adjusted basis. For more information on how to calculate the Sharpe Ratio, see our latest blog What is the Sharpe Ratio.
In the volatile markets we are facing at the moment, outperforming the market (or your strategy’s benchmark) on a risk-adjusted basis may be more important than having outright higher returns. With the high volatility we are currently experiencing, returns could be changing significantly every day. The presentation of returns without consideration, discussion, and demonstration of risk only tells one part of the story.
By including risk as a second dimension of performance you will be able to exhibit skill over luck and demonstrate how your strategy is prepared to perform regardless of the market conditions we face over the coming months and years.
Tools to Calculate Risk Statistics
Depending on your strategy, there are a number of other statistics that can help you analyze how your investment performance has fared through the current market conditions. If you would like to calculate some of these measures on your own, please see Longs Peak’s Performance Appraisal Statistics Cheat Sheet for formulas.
In addition, Longs Peak calculates performance appraisal measures and risk statistics for our clients that can be used internally as part of your portfolio management feedback loop, and externally to help demonstrate the success of your active management to clients and prospects. Below are some samples of the reports we create. We would be happy to calculate or discuss any of these statistics with your firm.


Questions?
If you have questions about investment performance and risk statistics, we would be love to help. Longs Peak’s professionals have extensive experience helping firms with their investment performance needs. We can do anything from providing ad-hoc investment performance calculations to operating as your fully outsourced investment performance team. Please to email Sean Gilligan directly at sean@longspeakadvisory.com for more information.

Investment Performance Outlier Testing
For any firm that aggregates portfolios of the same strategy into a composite, or otherwise groups portfolios by mandate, how do you know that each portfolio truly follows that strategy? The answer is outlier testing.
Why Utilize Composites?
The GIPS standards require firms managing separate accounts to construct composites, which aggregate all discretionary portfolios of the same strategy. However, even for firms that are not GIPS compliant, the use of composites is considered best practice when reporting investment performance to prospective clients. Composites offer a more complete picture than presenting performance of a model or “representative portfolio” – which usually leave prospects wondering whether the information is truly representative or if the portfolio presented was “cherry picked.”
When creating and maintaining composites, firms must ensure that portfolios are included in the correct composite for the right time period – the period for which you had full discretion to implement the composite strategy for that portfolio. This is achieved by following a clearly documented set of policies and procedures for composite inclusion and exclusion. However, what happens when changes are made to a portfolio and those changes are not communicated to the person maintaining the composite?
In an ideal world, information in your firm would flow perfectly so that the person maintaining your composites knows exactly what is happening with the firm’s clients. In reality, client requests commonly result in small or temporary changes to the portfolio (e.g., halt trading, raise cash) that are not formally documented in the client’s investment guidelines or investment policy statement.
Without formal documentation of these changes, information may not flow down to the manager of your composites. While these minor or temporary changes may not affect the client’s long-term objectives, they may cause the portfolio to deviate from the strategy, requiring (at least temporary) removal from its composite. When these restricted portfolios are left in the composite, they often become performance outliers and create “noise” in the composite results. This “noise” prevents the composite from providing a meaningful representation of the portfolio manager’s ability to implement the strategy. This will also interfere with your prospective clients’ ability to analyze and interpret your performance results.
Why test for performance outliers?
Testing for performance outliers prior to finalizing and publishing performance results can help your firm remove this “noise” and can prevent costly errors in performance presentations. Firms that lack adequate composite construction policies and controls to ensure the policies are consistently followed often end up with errors in their composite presentations. In fact, it is very likely that errors in your performance exist. It is rare for us at Longs Peak to conduct an outlier analysis where no issues are found. Outlier testing should be completed quarterly and at a minimum, before any related verification or performance examination.
Many firms, especially those that are GIPS compliant, rely on their verifier to catch errors in their composites. We do not recommend this and suggest firms perform testing internally (or with the help of a performance consultant like Longs Peak) because:
- Verifiers only test a sample and will likely not catch all of your issues.
- Verification may happen months after the performance has been published. When errors are found, it may require redistribution of presentations with disclosures regarding prior performance errors.
- When verifiers find errors, they generally increase their sample size as well as their assessment of engagement risk. These two things lead to more time spent on the verification and a potential increase in your verification fee.
Even if not GIPS compliant, when firms use composites, regulators may test to ensure the composites are a meaningful representation of the strategy. In addition to improving accuracy, testing for performance outliers can help your firm‘s composites meet the standards expected by regulators.
How can performance outliers be identified?
Testing for performance outliers involves reviewing the performance of portfolios within the same composite or strategy to test if they are performing similarly. This testing allows you to flag any portfolios that may be performing differently so you can evaluate if their inclusion in the composite is appropriate.
For example, if your firm has a Large Cap Growth composite, testing performance outliers would involve compiling the return data for all of your Large Cap Growth portfolios, identifying which portfolios performed materially different from their peers, researching why they performed differently, and then taking the appropriate action if an issue is discovered. This may sound like a daunting task, but it doesn’t have to be. Let us walk you through this in more detail.
Some firms simply look at the absolute difference between each portfolio’s monthly return and the monthly return of the composite. While this may be straight forward, relying only on the absolute difference to determine outliers does not take into consideration the size of the return and the normal distribution of portfolio returns in the composite. For example, if you set a threshold to look at all portfolios that deviate from the composite return by 50bps, the result for a composite with low dispersion and a total return of 2% would very be different than a composite with higher dispersion and a total return of 20%.
In the outlier analysis Longs Peak conducts for clients, we use standard deviation in conjunction with a comparison of the absolute differences to identify the outlier portfolios that require review. Utilizing standard deviation allows us to identify portfolios that are truly outside the normal distribution of returns for each period. For example, reviewing all portfolios that are more than 3 standard deviations from the composite mean will provide the portfolios outside the normal distribution of returns for that period, regardless of the size of the return or the level of dispersion in that composite.
What to consider when reviewing outlier performance
The severity of the outlier
The larger the outlier, the more likely it is that the portfolio has an issue that would require it to be removed from the composite. We typically start by looking at the most extreme outliers first. Generally, we look at portfolios with performance periods flagged with +/-3 standard deviations from the mean return for the period. By addressing these first (including removing them if it is determined they do not belong in the composite), we are able to re-run the outlier test to assess what outliers exist without these extreme cases disrupting the analysis.
Once these extreme outliers are addressed, we move on to review the portfolios that are +/-2 standard deviations and even +/-1.5 standard deviations, if needed. We keep reviewing accounts with returns closer and closer to the composite’s mean return until we are consistently confirming that the portfolios do in fact belong in the composite and errors are not being found.
Each firm will be different in how much they need to drill down to get to a point of comfort that no more errors exist. If your composite is managed strictly to a model, the outliers will be very clear and easy to identify. If each portfolio you manage is customized, more research is often needed to determine if the outlier performance is simply a result of the portfolio’s customization or if the portfolio was included in the wrong composite.
How often the portfolio is an outlier
Longs Peak’s performance outlier reports show a portfolio’s performance, the number of standard deviations it is from the mean each month, and the number of months the portfolio was an outlier throughout its history in that composite. Our reports also show whether there was a cash flow during that period or not. The following are examples of outlier frequencies we evaluate:
Infrequent: If you see that a portfolio is only an outlier for one month and that month had a large cash flow, then you will know that the portfolio is likely only an outlier for that period because of the cash flow and, often, no further research is required.
Frequent: If you can see that the portfolio is an outlier for most of the months under review, then you will know that there is likely an issue with this portfolio.
As of a specific date: If you can see that the portfolio was not an outlier historically, but became a frequent outlier from a certain month forward, this may indicate that a restriction was added or that the strategy changed as of that period. The portfolio may then need to be reclassified to the appropriate composite or flagged as non-discretionary.
The most common causes of outlier performance and how to address performance outliers
Common causes of outlier performance:
- Data issues – When outliers are extreme, it is likely that there is an issue with the data. Examples include a pricing issue that caused a material jump in performance or a late dividend hitting a portfolio that is closing and had most of its assets already transferred out. These issues are often easily addressed, depending on the circumstance of each case.
- Cash flows – If a portfolio is only an outlier for one month and during that month the portfolio experienced a large cash flow, this is likely the reason for the outlier performance. If the portfolio had high cash for a period of time around the cash flow and the market moved during that period, this portfolio likely would perform differently than its fully invested peers. Nothing needs to be done in this scenario since the outlier performance is explained and there is no indication that the portfolio is invested incorrectly or grouped with the wrong portfolios.
- Legacy positions or other client restrictions – If your clients hold legacy positions that you are restricted from selling or have other similar restrictions, this will likely cause these portfolios to perform differently when compared to their unrestricted peers. Depending on your composite construction rules, unless immaterial, these portfolios likely need to be excluded from the composite. With these portfolios removed, other outliers may appear that were not as noticeable when the restricted portfolios were included. It is important to refer to your firm’s composite construction policies, which should outline clear parameters for when restricted portfolios should be included/excluded in composites.
- Portfolio categorized incorrectly – A portfolio may appear as an outlier because it was placed in the wrong composite. This often happens if a portfolio’s composite changed and it was not removed from its prior composite. If this is the case, the portfolio must be removed (after the change) and added to the new composite based on the timing outlined in your firm’s composite construction policies.
- Portfolio managed incorrectly – Performance outlier analysis may help identify a portfolio that is managed to the wrong strategy. For example, it is possible that the portfolio is grouped with the correct portfolios, but the wrong strategy was implemented in the portfolio. This is one of the most important errors that performance outlier testing can identify because it means that the client is actually not having their money managed to the strategy for which your firm was hired. In this case, the portfolio would need to be rebalanced to the correct strategy. Likely, a review of the history would need to be conducted as well to ensure the client was not disadvantaged by the error.
- High dispersion between portfolio managers – Especially when more than one portfolio manager is implementing the same composite at your firm, material differences may exist in the way they each manage the strategy. Outlier performers may be due to differences in the portfolio managers’ discretionary management. If the composite is being sold as one cohesive product, it is important to identify where the portfolio managers deviate and determine if they can work more closely together to avoid high dispersion or if the strategy should actually be run as two different products.
When researching outlier performance, keep in mind that, on its own, a portfolio’s performance deviating from its peers is not a valid reason to remove the portfolio from its composite. You need to determine the root cause of the deviation and remove the portfolio from its composite only if the root cause was client-driven. If the deviation was caused by tactical, discretionary moves made by the portfolio manager, the portfolio must remain in the composite as its performance is still a representation of the portfolio manager’s implementation of the strategy.
Ready to implement performance outlier testing at your firm?
While it is best practice to create a flow of information that will allow portfolios to proactively be included/excluded in the correct composite at the appropriate time, testing for performance outliers acts as a back-up plan to catch anything that was missed.
If analyzing your composite data to identify performance outliers is not something you have the resources to do internally, Longs Peak is available to help. Longs Peak offers both consulting and reporting services that can assist your firm with outlier analysis. Conducting outlier analysis should be done at least quarterly to help ensure your firm is managing your portfolios consistently and are reporting strategy or composite performance that is meaningful and accurate. Please contact us to discuss how we can help implement this practice for your firm.
Questions?
If you have questions about investment performance, composite construction, or the GIPS standards, we would be love to talk to you. Longs Peak’s professionals have extensive experience helping firms with all of their investment performance needs. Please feel free to email Sean Gilligan directly at sean@longspeakadvisory.com.

2020 GIPS Standards: Prepare for the Changes
The 2020 edition of the Global Investment Performance Standards (“GIPS®”) was released to the public at the end of June 2019 and with it comes a number of changes that firms will need to address. To maintain compliance with the GIPS standards, firms must make the required changes necessary to follow all requirements of the 2020 GIPS standards prior to presenting information through 31 December 2020 in their firm’s GIPS Reports.
All firms and asset owners complying with the GIPS standards will be required to at least make some changes to disclosures and the terminology used in their GIPS policies and procedures. Some firms will require more work. The following questionnaire is designed to help firms determine if converting to the 2020 GIPS standards will require more than a few minor tweaks for their firm. This list does not include all changes, but includes the top ten material changes that may require a project plan to be put in place to be able to implement the required changes by the effective date of the 2020 GIPS standards.
If your firm answers “Yes” to any of the following questions, a project plan should be established to address how the 2020 changes will be implemented at your firm prior to presenting 2020 performance in your firm’s GIPS Reports:
Key Questions to Consider
- Does your firm have limited distribution pooled funds (i.e., private funds that are not regulated under a framework that would permit the general public to purchase shares in the fund without a one-on-one presentation)?
- Has your firm created single account composites for pooled funds solely for the purpose of meeting the GIPS requirement of having every discretionary, fee-paying portfolio in at least one composite?
- Does your firm have multi-strategy portfolios (e.g., balanced portfolios where the equity and fixed income segments each could be represented as standalone strategies) where you would like to carve-out the individual strategies into their own composites?
- Does your firm have portfolios where actual transaction costs are unavailable (e.g., wrap accounts or other bundled fee arrangements)?
- Does your firm have portfolios where your firm controls the amount and timing of external cash flows (other than for private equity or real estate)?
- Does your firm have real estate or private equity composites?
- Does your firm include theoretical performance (e.g., model performance) as part of a GIPS report?
- Does your firm follow the Advertising Guidelines to claim compliance with the GIPS standards outside of your GIPS reports?
- Does your firm currently update your GIPS compliant presentations more than 12 months after the year ends?
- Does your firm have advisory-only assets or uncalled committed capital you wish to present in your GIPS Report?
Need Help Navigating or Implementing the 2020 GIPS Standards?
As a consulting firm specialized in investment performance and the GIPS standards, Longs Peak Advisory Services (“Longs Peak”) is available to help implement the 2020 GIPS standards for your firm. Verification firms are required to remain independent, which means they can provide your firm with advice, but they cannot actually “get their hands dirty” making the changes for you.
Whether you answered “Yes” to any of the questions above or if you just need help with the minor tweaks all firms need to make, Longs Peak is available to help. Please reach out to us and we can create a project plan to help your firm prepare to comply with all requirements of the 2020 GIPS standards.

GIPS 2020: What’s Changing and What You Should Do (Updated July 2019)
It has been a busy couple of weeks for GIPS! On August 31st, the Exposure Draft of the 2020 Global Investment Performance Standards (GIPS®) was released for public comment and last week (September 14th and 15th) was the GIPS conference. With this exposure draft being released only two weeks before the conference, the forthcoming changes to the GIPS standards were the highlight of the event.
UPDATE: Notes have been added in red to clarify what has been adopted or modified now that the 2020 GIPS standards have been published.
Why are changes to the GIPS standards necessary?
The three primary reasons GIPS standards are being revised is to make them:
- Easier to understand: GIPS compliant firms are required to comply with all of the requirements of GIPS, including issues addressed in Guidance Statements and Q&A’s. Since the 2010 Standards were published, there have been several new Guidance Statements and many Q&A’s issued, which can be difficult for firms to follow. The GIPS 2020 re-write of the Standards is reorganized to avoid having to refer to several different sources to understand what is required.
- More relevant for different types of investors: GIPS was intended to be a global standard that is applicable to any type of investment manager, regardless of location or type of investment strategy managed. Despite this intention, GIPS has historically been focused on presenting composite performance, which is only really relevant when marketing a strategy to prospective segregated account investors. GIPS 2020 differentiates between marketing a strategy to potential segregated account investors versus marketing an established pooled fund to prospective fund investors. It also separates out the requirements for Asset Owners who present performance to their oversight board instead of prospective investors.
- More consistent across asset classes: In some cases, the Standards have been overly focused on asset class in specifying calculation methodology and valuation requirements where investment vehicle structure and external cash flow control are perhaps more important than the underlying investments. By removing asset class specific requirements for private equity and real estate, the Standards can be applied more appropriately and in a more consistent manner.
What is changing with GIPS?
To be clear, nothing is changing yet. The purpose of the exposure draft is to introduce proposed changes. We are all invited to provide comments during the public comment period (open through December 31, 2018) to ensure our voices are heard before any of these proposed changes become official. Below are some highlights of the most significant proposed changes:
Asset Owners
While this is largely just a formatting change, the reorganization of how the requirements for Asset Owners are documented will make it significantly easier for Asset Owners to understand and apply GIPS to their organizations. Specifically, GIPS 2020 separates the requirements for Investment Management Firms and Asset Owners, allowing each type of firm to review the provisions applicable to them and see all requirements in one place. Since there are many redundancies between the two sections, this makes the Standards much longer, but easier to read since only the sections of the provisions applicable to them needs to be reviewed. Previously, Asset Owners were required to start with the Standards that were written for investment managers and then remove or adjust the requirements that were not applicable for them. It is now easier for Asset Owners to understand what applies.
UPDATE: This change was adopted as part of the 2020 GIPS standards.
Managers of Pooled Funds
Previously, GIPS compliant firms were required to create composites for pooled funds even if the pooled fund would be the only constituent of the composite. GIPS 2020 no longer requires these composites to be created. Managers of limited distribution pooled funds will instead create a GIPS Pooled Fund Report that presents the information of the fund itself for prospective investors together with required GIPS disclosures for this type of report. Managers of broadly distributed pooled funds are not required to create a special report for GIPS. This will save managers of pooled funds a lot of time and effort and will allow them to create meaningful presentations focused on the funds themselves rather than creating composites that would likely never be used.
UPDATE: This change was adopted as part of the 2020 GIPS standards.
Option to present MWR
Previously, only Private Equity funds presented Money-Weighted Returns (“MWR”) (a.k.a. Internal Rates of Return (“IRR”)). GIPS 2020 removes all asset class specific rules and focuses more on the structure of cash flows and the type of vehicle used. For example, under GIPS 2020, if a firm manages a closed end fund where they control the external cash flows, they will have the option to present MWR instead of TWR, regardless of the type of underlying investments being made. In cases where the manager controls the timing and amount of the cash flows rather than the client, MWR is likely a more meaningful performance measure since it does not remove the effect of the cash flows the way TWR does.
UPDATE: This change was adopted as part of the 2020 GIPS standards.
Valuation Requirements
Previously only the Real Estate provisions included a requirement for external valuations. Since all asset class specific rules have been removed, the external valuation requirement now applies to all private market investments. To make this manageable, what is accepted as an “external valuation” has been loosened to include annual financial statement audits. This means that as long as the fund is audited, no separate external valuation should be required.
UPDATE: This was NOT fully adopted. Private market investments are now RECOMMENDED to have an external valuation at least every 12 months; however, real estate investments included in a real estate open-end fund are still required to have external valuations at least every 12 months. Real estate investments that are not included in real estate open-end funds are required to have an external valuation at least every 12 months unless the client agrees to a less frequent external valuation (minimum of every 36 months) OR, instead of the external valuation, the real estate investment can be subject to an annual financial statement audit.
Carve-outs
That’s right, carve-outs are back! Firms that spent a lot of time and money revising their composites when carve-outs were disallowed in 2010 may not be happy to hear this, but this is likely good news for wealth management firms with balanced accounts that want to market asset class specific strategies. It is not yet clear whether carve-outs can be built historically covering the period they were disallowed (2010 – 2020), but this was discussed at the GIPS conference and we expect it to be clarified.
UPDATE: This change was adopted as part of the 2020 GIPS standards and updates can be made for historical periods once the firm has adopted the 2020 GIPS standards.
Portability
Under the current Standards, GIPS requires firms to link prior track records to ongoing performance if all of the portability requirements are met. GIPS 2020 proposes to make the linking of historical performance optional.
UPDATE: This change was adopted as part of the 2020 GIPS standards.
Advisory-Only Assets
Firms are required to report total firm assets that include the assets of both discretionary and non-discretionary portfolios. GIPS 2020 clarifies that advisory-only assets cannot be presented as a part of total firm assets, but may be presented separately. With the growth of Unified Managed Account (UMA) platforms, many firms’ assets are shifting to the “advisory-only” category. Although presented separately from total firm assets, being able to present these advisory-only assets will allow firms with a large UMA business to demonstrate the amount of assets invested in their models.
UPDATE: This change was adopted as part of the 2020 GIPS standards.
Deadline to Update GIPS Presentations
GIPS Composite Reports (formerly known as Compliant Presentations) will need to be updated with the latest annual statistics within 6 months after the annual period ends. This won’t be an issue for most firms, but firms who prefer to have their verification complete prior to updating their presentations may struggle to get this updated in time.
UPDATE: A deadline to update GIPS Reports was adopted as part of the 2020 GIPS standards; however, a more reasonable 12 months after the annual period ends was set instead of the proposed 6 month deadline.
Sunset Provisions for Select Disclosures
GIPS 2020 will allow some disclosures, such as disclosures of benchmark changes or material events to be removed when they are no longer relevant for current prospects.
UPDATE: This change was adopted as part of the 2020 GIPS standards.
Additional Statistic in GIPS Presentations
GIPS 2020 will require a 3-year annualized return to be presented for both the composite and benchmark. GIPS already requires the 3-year annualized ex post standard deviation to be presented for the composite and benchmark, so this provides the return that matches the periods included in the standard deviation calculation.
UPDATE: This change was NOT adopted as a requirement of the 2020 GIPS standards, but was instead adopted as a recommendation.
Estimated Transaction Costs
Previously, the use of estimated transaction costs was prohibited. Because of this, many wrap managers, or managers of accounts with asset-based transaction fees that do not reduce gross-of-fee returns, are required to present their gross-of-fee returns as supplemental information. As long as these firms are able to estimate the transaction costs and support that the estimated costs result in gross-of-fee performance that is lower than when using actual transaction costs, these managers will be able to present gross-of-fee returns without the supplemental disclosures under GIPS 2020.
UPDATE: This change was adopted as part of the 2020 GIPS standards; however, the requirement for calculating returns that are more conservative when using estimated transaction costs was removed because it may be too difficult to prove. It was clarified that estimated transaction costs may only be used when actual transaction costs are unknown. Guidance on how to determine estimated transaction costs will be included in the Handbook, which is expected to be published by the end of 2019.
Revised Advertising Guidelines
GIPS 2020 takes a broader approach to the Advertising Guidelines to include advertisements to Pooled Fund Investors and Asset Owners rather than only for composites intended for Segregated Account Investors. Additionally, the requirements were loosened by changing some of the previously required disclosures to recommendations and by increasing the options for performance periods presented.
UPDATE: This change was adopted as part of the 2020 GIPS standards.
What action should be taken now?
UPDATE: The 2020 GIPS standards are now published. Please see our latest blog “2020 GIPS Standards: Prepare for the Changes“ to help your firm determine what steps you need to take to comply with the 2020 edition of the GIPS Standards.
The changes listed above are a sample of the most significant changes. If you are concerned about the changes, I would strongly encourage you to review the full exposure draft and provide comments to the GIPS Executive Committee. Read the full Exposure draft and provide any comments to the following email: standards@cfainstitute.org. Comments must be submitted by December 31, 2018.
Please note that the exposure draft contains 47 specific questions that the GIPS Executive Committee would like feedback on prior to finalizing the changes. You can provide comments on as many or as few of those questions as you like. Additionally, you can feel free to provide comments on any aspect of the Standards even if not related to one of the questions posed. Keep in mind that providing positive responses to what you do like is as important as providing critical feedback. If only critical feedback is provided, there is the risk that changes could be made based on the critical responses received that actually represent a minority of the stakeholders’ opinions since they did not hear the positive support for the change.
Questions?
If you have questions about GIPS 2020 or the Standards in general, we would love to talk to you. Longs Peak’s professionals have extensive experience helping firms become GIPS compliant as well as helping firms maintain their compliance with GIPS on an ongoing basis. Please feel free to email Sean Gilligan directly at sean@longspeakadvisory.com.

Today, September 3, 2018, Longs Peak turns 3 years old! Over the last 3 years we have provided investment performance and GIPS consulting services to over 70 investment firms and we are proud that, for many of these firms, we helped them claim compliance with the GIPS standards for the first time.
To celebrate this occasion, instead of writing a technical blog about performance and GIPS, I’d like to share what this date means to me each year.
September 3rd was not an arbitrary date to launch our firm. This date is significant to me because on September 3rd 2003 I had my first open heart surgery to repair an aortic aneurysm and to replace my aortic valve with a valve from a pig. Exactly ten years later, on September 3rd 2013, I had a second open heart surgery to replace my pig valve with a valve from a cow because my pig valve had torn.
Going through these surgeries and the recovery periods that followed was not easy, but I made a conscious decision to embrace being part farm animal and focus on the positive. These experiences motivated me to live my life to its fullest potential. This means something different to everyone, but for me, this meant taking chances to ensure I didn’t look back on my life wishing I’d had the courage to do something I was too scared to try. One of the biggest chances I took was leaving a great job to start Longs Peak. This was one of the scariest decisions I’ve ever made, but it has been one of the most rewarding adventures of my life, thanks to our wonderful clients and amazing team.
Over the years, this mentality has pushed to make decisions that help me truly experience life outside of work as well. Specifically, on or around September 3rd each year, I celebrate my life and health by doing something I would not have been able to do if it weren’t for the success of these surgeries. In previous years I have run a marathon, completed long hikes, and climbed 14ers (mountains in Colorado above 14,000 feet), but this year I am taking it to a new level!
With this year being both the 5th and 15th anniversaries of my two surgeries, I was looking for a big physical challenge as well as a way to encourage the people around me to live long, healthy, and satisfying lives. This year, I have decided to climb Mount Kilimanjaro as a fundraiser for the American Heart Association, which I will do during the second half of this month.

The American Heart Association’s mission is to be a relentless force for a world of longer, healthier lives. Without the hard work of organizations like this, the idea of putting parts of farm animals into people would sound ridiculous. Actually, it still does sound ridiculous, but it works, and it gives people like me the opportunity to live full and complete lives.
I would love to have your support in this adventure. If you are interested in contributing to the fundraiser, donations of any amount are greatly appreciated and can be made through the link below. Please note that as my contribution to this cause I will personally match all donations up to $2,500.
Link to fundraiser page: Gilly Does Kili


