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COMPARISON MATRIX

1999 GIPS STANDARDS V. REVISED GIPS STANDARDS


1999 GIPS STANDARDS REVISED GIPS STANDARDS
Fundamentals of Compliance - Requirements
Intro 12. Definition of a Firm GIPS must be applied on a 0.A.1 The GIPS standards must be applied on a
firmwide basis. firm wide basis.
Intro 12. A firm may define itself as: 0.A.2 Firms must be defined as an investment
a. an entity registered with the appropriate national firm, subsidiary, or division held out to clients or
regulatory authority overseeing the entity’s investment potential clients as a distinct business entity.
management activities; or
b. an investment firm, subsidiary, or division held out to
clients or potential clients as a distinct business unit (e.g.,
a subsidiary firm or distinct business unit managing
private client assets may claim compliance for itself
without its parent organization being in compliance).
c. (until January 1, 2005), all assets managed to one or
more base currencies (for firms managing global assets).
0.A.3 Total firm assets must be the aggregate of
the market value of all discretionary and non-
discretionary assets under management within the
defined firm. This includes both fee-paying and
non-fee-paying assets.
0.A.4 Firms must include the performance of
assets assigned to a sub-advisor in a composite
provided the firm has discretion over the selection of
the sub-advisor.
0.A.5 Changes in a firm's organization are not
permitted to lead to alteration of historical composite
results.
Intro 15: Firms are strongly encouraged to perform 0.A.6 Firms must document, in writing, their
periodic internal compliance checks and implement policies and procedures used in establishing and
adequate business controls on all stages of the investment maintaining compliance with all the applicable
performance process-from data input to presentation requirements of the GIPS Standards.
material-to ensure the validity of compliance claims.
Intro 17. Claim of Compliance. Once a firm has met all 0.A.7 Once a firm has met all of the required
of the required elements of GIPS, the firm may use the elements of the GIPS Standards, the firm must use
following “Compliance Statement” to indicated that the the following compliance statement to indicate that
performance presentation is in compliance with GIPS: the firm is in compliance with the GIPS Standards:

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1999 GIPS STANDARDS REVISED GIPS STANDARDS
[Insert name of firm] has prepared and presented this “(Insert name of firm) has prepared and presented
report in compliance with the Global Investment this report in compliance with the Global Investment
Performance Standards (GIPS). Performance Standards (GIPS®)”.
Intro 17. If the performance presentation does not meet 0.A.8 If the firm does not meet all of the
all of the requirements of GIPS, firms cannot represent requirements of the GIPS Standards, the firm cannot
that the performance presentation is “in compliance with represent that it is “in compliance with the Global
the Global Investment Performance Standards except Investment Performance Standards except for...”
for...”
Intro 17. Statements referring to the calculation 0.A.9 Statements referring to the calculation
methodology used in a presentation as being “in methodology used in a composite presentation as
accordance (or compliance) with the Global Investment being “in accordance (or compliance) with the
Performance Standards” are prohibited … Global Investment Performance Standards” are
prohibited.
Intro 17. … except when applied to the performance of a 0.A.10 Statements referring to the performance of
single, existing client. a single, existing client as being “calculated in
accordance with the Global Investment Performance
Standards” are prohibited except when a GIPS-
compliant firm reports the performance of an
individual account to the existing client.
0.A.11 Firms must make every reasonable effort to
provide a compliant presentation to all prospective
clients, i.e., firms cannot choose to whom they want
to present compliant performance. (As long as a
prospective client has received a compliant
presentation within the previous 12 months, the firm
has met this requirement.)
0.A.12 Firms must provide a list and description of
composites to any prospective client that makes such
a request (a sample list and description of
composites is included in Appendix B). Firms must
list “discontinued” composites on the firm’s list of
composites for at least 5 years after discontinuation.

0.A.13 Firms must provide a compliant


presentation for any composite listed on the firm’s
list and description of composites to any prospective
client that makes such a request.
0.A.14 When the firm jointly markets with other
firms, the firm claiming compliance with the GIPS

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1999 GIPS STANDARDS REVISED GIPS STANDARDS
Standards must be sure that it is clearly defined and
separate, relative to any other firms being marketed
and that it is clear which firm is claiming
compliance
0.A.15 Firms are encouraged to comply with the
recommendations and must comply with all
applicable requirements of the GIPS Standards,
including any updates, reports, Guidance
Statements, interpretations, or clarifications
published by CFA Institute and the Investment
Performance Council which will be made available
via the CFA Institute website (www.cfainstitute.org)
as well as the GIPS Handbook.
Fundamentals of Compliance - Recommendations
0.B.1 Firms are encouraged to adopt the broadest,
most meaningful definition of the firm. The scope
of this definition should include all geographic
(country, regional, etc.) offices operating under the
same brand name regardless of the actual name of
the individual investment management companies.
0.B.2 Firms are encouraged to undertake the
verification process, defined as the review of a
firm’s performance measurement processes and
procedures by an independent third-party verifier. A
single verification report is issued in respect to the
whole firm; verification cannot be carried out for a
single composite. The primary purpose of
verification is to establish that a firm claiming
compliance with the GIPS Standards has adhered to
the Standards.
0.B.3 Firms that have been verified are
encouraged to add a disclosure to composite
presentations or advertisements stating that the firm
has been verified. Firms must disclose the periods
of verification if the composite presentation includes
results for periods that have not been subject to firm
wide verification. The verification disclosure
language should read: “(Insert name of firm) has
been verified for the periods (insert date) by (name

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1999 GIPS STANDARDS REVISED GIPS STANDARDS
of verifier). A copy of the verification report is
available upon request”.
Input Data - Requirements
1.A.1 All data and information necessary to support a 1.A.1 All data and information necessary to
firm’s performance presentation and to perform the support a firm’s performance presentation and to
required calculations must be captured and maintained. perform the required calculations must be captured
and maintained.
1.A.2 Portfolio valuations must be based on market 1.A.2 Portfolio valuations must be based on
values (not cost basis or book values). market values (not cost basis or book values).
1.A.3 Portfolios must be valued at least quarterly. For 1.A.3 For periods prior to 1 January 2001,
periods beginning 1 January 2001, portfolios must be portfolios must be valued at least quarterly. For
valued at least monthly. For periods beginning 1 January periods between 1 January 2001 and 1 January 2010,
2010, it is anticipated that firms will be required to value portfolios must be valued at least monthly. For
portfolios on the date of any external cash flow. periods beginning 1 January 2010, firms must value
portfolios on the date of all large external cash
flows.
1.A.4 Firms must use trade-date accounting beginning 1.A.5 For periods beginning 1 January 2005,
January 1, 2005. firms must use trade date accounting.

1.A.5 Accrual accounting must be used for fixed-income 1.A.6 Accrual accounting must be used for fixed
securities and all other assets that accrue interest income. income securities and all other assets that accrue
-- Combined With -- interest income. Market values of fixed income
2.A.3 In both the numerator and the denominator, the securities must include accrued income.
market values of fixed-income securities must include
accrued income.
1.A.6. Accrual accounting must be used for dividends (as 1.B.1 Accrual accounting should be used for
of the ex-dividend date) beginning 1/1/2005. dividends (as of the ex-dividend date).
1.A.7 For periods beginning 1 January 2006,
composites must have consistent beginning and
ending annual valuation dates. Unless the composite
is reported on a non-calendar fiscal year, the
beginning and ending valuation dates must be at
calendar year-end (or on the last business day of the
year).
1.A.4 For periods beginning 1 January 2010, firms
must value portfolios as of the calendar month-end
or the last business day of the month.
Input Data - Recommendations

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1.B.1 Sources of exchange rates should be the same for
the composite and the benchmark.
1.B.2 When presenting net-of-fees returns, firms
should accrue investment management fees.
1.B.3 Calendar month-end valuations or valuations
on the last business day of the month are
recommended.
Calculation Methodology - Requirements
2.A.1. Total return, including realized and unrealized 2.A.1 Total return, including realized and
gains plus income, must be used. unrealized gains and losses, plus income, must be
used.
2.A.2 Time-weighted rates of return that adjust for cash 2.A.2 Time-weighted rates of return that adjust
flows must be used. Periodic returns must be for external cash flows must be used. Periodic
geometrically linked. Time-weighted rates of return that returns must be geometrically linked. External cash
adjust for daily-weighted cash flows must be used for flows must be treated in a consistent manner with
periods beginning January 1, 2005. Actual valuations at the firm’s documented, composite-specific policy.
the time of external cash flows will likely be required for At a minimum:
periods beginning 1 January 2010. (a) For periods beginning 1 January 2005, firms
-- Combined With -- must use approximated rates of return that adjust for
2.B.2 Performance adjustments for external cash flows daily-weighted external cash flows.
should be treated in a consistent manner. Significant cash (b) For periods beginning, 1 January 2010, firms
flows (i.e. 10 percent of the portfolio or greater) that must value portfolios on the date of all large external
distort performance (i.e. plus or minus .02 percent for the cash flows
period) may require portfolio revaluation on the date of
the cash flow (or after investment) and the geometric
linking of subperiods. Actual valuations at the time of
external cash flows will likely be required for periods
beginning 1 January 2010.
2.A.3 In both the numerator and the denominator, the Incorporated into 1.A.6.
market values of fixed-income securities must include
accrued income.
2.A.4. Composites must be asset-weighted using 2.A.3 Composite returns must be calculated by
beginning-of-period weightings or another method that asset-weighting the individual portfolio returns using
reflects both beginning market value and cash flows. beginning-of-period values or a method that reflects
both beginning-of-period values and external cash
flows.
2.A.5. Returns from cash and cash equivalents held in 2.A.4 Returns from cash and cash equivalents
portfolios must be included in total return calculations. held in portfolios must be included in total return
calculations.

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1999 GIPS STANDARDS REVISED GIPS STANDARDS
2.A.6: Performance must be calculated after the 2.A.5 All returns must be calculated after the
deduction of all trading expenses. deduction of the actual trading expenses incurred
during the period. Estimated trading expenses are
not permitted.
2.A.7. If a firm sets a minimum asset level for portfolios 3.A.9 If the firm sets a minimum asset level for
to be included in a composite, no portfolios below that portfolios to be included in a composite, no
asset level can be included in that composite. portfolios below that asset level can be included in
that composite. Any changes to a composite-
specific minimum asset level are not permitted to be
applied retroactively.
2.A.6 For periods beginning 1 January 2006,
firms must calculate composite returns by asset-
weighting the individual portfolio returns at least
quarterly. For periods beginning 1 January 2010,
composite returns must be calculated by asset-
weighting the individual portfolio returns at least
monthly.
2.A.7 If the actual direct trading expenses cannot
be identified and segregated from a bundled fee:
(a) when calculating gross-of-fees returns, returns
must be reduced by the entire bundled fee, or the
portion of the bundled fee that includes the direct
trading expenses. The use of estimated trading
expenses is not permitted.
(b) when calculating net-of-fees returns, returns
must be reduced by the entire bundled fee, or the
portion of the bundled fee that includes the direct
trading expenses and the investment management
fee. The use of estimated trading expenses is not
permitted.
Calculation Methodology - Recommendations
2.B.1. Returns should be calculated net of non- 2.B.1 Returns should be calculated net of non-
reclaimable withholding taxes on dividends, interest, and reclaimable withholding taxes on dividends, interest,
capital gains. Reclaimable withholding taxes should be and capital gains. Reclaimable withholding taxes
accrued. should be accrued.
2.B.2 Firms should calculate composite returns
by asset-weighting the member portfolios at least
monthly.
2.B.3 Firms should value portfolios on the date of

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all large external cash flows.
Composite Construction – Requirements
3.A.1 All actual fee-paying discretionary portfolios must 3.A.1 All actual, fee-paying, discretionary
be included in at least one composite. portfolios must be included in at least one
composite. While non-fee-paying discretionary
portfolios may be included in a composite (with
appropriate disclosures), non-discretionary
portfolios are not permitted to be included in a
firm’s composites.
3.A.2. Firm composites must be defined according to 3.A.2 Composites must be defined according to
similar investment objectives and/or strategies. similar investment objectives and/or strategies. The
full composite definition must be made available on
request.
3.A.3. Composites must include new portfolios on a 3.A.3 Composites must include new portfolios on
timely and consistent basis after the portfolio comes a timely and consistent basis after the portfolio
under management - unless specifically mandated by the comes under management unless specifically
client. mandated by the client.
3.A.4. Terminated portfolios must be included in the 3.A.4 Terminated portfolios must be included in
historical record of the appropriate composites up to the the historical returns of the appropriate composites
last full measurement period that the portfolio was under up to the last full measurement period that the
management. portfolio was under management.
3.A.5. Portfolios must not be switched from one 3.A.5 Portfolios are not permitted to be switched
composite to another unless documented changes in from one composite to another unless documented
client guidelines or the redefinition of the composite changes in client guidelines or the redefinition of the
make switching appropriate. The historical record of the composite make it appropriate. The historical record
portfolio must remain with the appropriate composite. of the portfolio must remain with the appropriate
composite.
3.A.6. Convertible and other hybrid securities must be 3.A.6 Convertible and other hybrid securities
treated consistently across time and within composites. must be treated consistently across time and within
composites.
3.A.7 Carve-out returns excluding cash cannot be used to 3.A.7 Carve-out segments excluding cash are not
create a stand-alone composite. When a single asset class permitted to be used to represent a discretionary
is carved out of a multiple-asset portfolio and the returns portfolio and, as such, are not permitted to be
are presented as part of a single-asset composite, cash included in composite returns. When a single asset
must be allocated to the carve-out returns and the class is carved out of a multiple asset class portfolio
allocation method must be disclosed. Beginning 1 and the returns are presented as part of a single asset
January 2005, carve-out returns must not be included in composite, cash must be allocated to the carve-out
single asset-class composite returns unless the carve-outs returns in a timely and consistent manner.
are actually managed separately with their own cash Beginning 1 January 2010, carve-out returns are not

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1999 GIPS STANDARDS REVISED GIPS STANDARDS
allocations. permitted to be included in single asset class
composite returns unless the carve-out is actually
managed separately with its own cash balance.
3.A.8. Composites must include only assets under 3.A.8 Composites must include only assets under
management and may not link simulated or model management within the defined firm. Firms are not
portfolios with actual performance. permitted to link simulated or model portfolios with
actual performance.
Composite Construction - Recommendations
3.B.1: Separate composites should be created to reflect
different levels of allowed asset exposure.
3.B.2: Unless the use of hedging is negligible, portfolios
that allow the use of hedging should be included in
different composites from those that do not.
3.B.1 Carve-out returns should not be included in
single asset class composite returns unless the carve-
outs are actually managed separately with their own
cash balance.
3.B.2 To remove the effect of a significant
external cash flow, the use of a temporary new
account is recommended (as opposed to adjusting
the composite composition to remove portfolios with
significant external cash flows).
3.B.3 Firms should not market a composite to a
prospective client with assets less than the
composite’s minimum asset level.
Disclosures - Requirements
4.A.1. The definition of “firm” used to determine the 4.A.1 Firms must disclose the definition of "firm"
firm’s total assets and firmwide compliance. used to determine the total firm assets and firm wide
compliance.
4.A.2. Total firm assets for each period. Incorporated into 5.A.1.c.
4.A.3 The availability of a complete list and description 4.A.2 Firms must disclose the availability of a
of all of the firm’s composites. complete list and description of all of the firm's
composites.
4.A.4 If settlement-date valuation is used by the firm.
4.A.5 The minimum asset level, if any, below which 4.A.3 Firms must disclose the minimum asset
portfolios are not included in a composite. level, if any, below which portfolios are not included
in a composite. Firms must also disclose any
changes to the minimum asset level.

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4.A.6 The currency used to express performance. 4.A.4 Firms must disclose the currency used to
express performance.
4.A.7. The presence, use and extent of leverage or 4.A.5 Firms must disclose the presence, use, and
derivatives, including a description of the use, frequency extent of leverage or derivatives, if material,
and characteristics of the instruments sufficient to including a description of the use, frequency, and
identify risks. characteristics of the instruments sufficient to
identify risks.
4.A.8 Whether performance results are calculated gross 4.A.6 Firms must clearly label returns as gross-of-
or net of investment management fees and other fees paid fees or net-of-fees.
by the clients to the firm or to the firm’s affiliates.
4.A.9. Relevant details of the treatment of withholding 4.A.7 Firms must disclose relevant details of the
tax on dividends, interest income, and capital gains. If treatment of withholding tax on dividends, interest
using indexes that are net of taxes, firms must disclose income and capital gains. If using indexes that are
the tax basis of the composite (e.g., Luxembourg based or net-of-taxes, the firm must disclose the tax basis of
U.S. based) versus that of the benchmark. the benchmark (e.g. Luxembourg based or U.S.
based) versus that of the composite.
4.A.10. For composites managed against specific
benchmarks, the percentage of the composites invested in
countries or regions not included in the benchmark.
4.A.11 Any known inconsistencies between the chosen 4.A.8 Firms must disclose and describe any known
source of exchange rates and those of the benchmark inconsistencies in the exchange rates used among the
must be described and presented. portfolios within a composite and between the
composite and the benchmark.
4.A.12 Whether the firm has included any non-fee- 5.A.7 If a composite contains any non-fee-paying
paying portfolios in composites and the percentage of portfolios, the firm must disclose, as of the end of
composite assets that are non-fee-paying portfolios. each annual period, the percentage of the composite
assets represented by the non-fee-paying portfolios.
4.A.13 Whether the presentation conforms with local 4.A.9 If the presentation conforms with local laws
laws and regulations that differ from GIPS requirements and regulations that differ from the GIPS
and the manner in which the local standards conflict with requirements, firms must disclose this fact and
GIPS. disclose the manner in which the local laws and
regulations conflict with the GIPS Standards.
4.A.14. For any performance presented for periods prior 4.A.10 For any performance presented for periods
to 1/1/2000 that does not comply with GIPS, the period prior to 1 January 2000 that does not comply with
of non-compliance and how the presentation is not in the GIPS Standards, firms must disclose the period
compliance with GIPS. of non-compliance and how the presentation is not
in compliance with the GIPS Standards.
4.A.15 When a single asset class is carved out of a 4.A.11 For periods prior to 1 January 2010, when a

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multiple-asset portfolio and the returns are presented as single asset class is carved out of a multiple asset
part of a single-asset composite, the method used to portfolio and the returns are presented as part of a
allocate cash to the carve-out returns. single asset composite, firms must disclose the
policy used to allocate cash to the carve-out returns.
4.A.13 If a composite contains portfolios with
bundled fees, firms must disclose for each annual
period shown the percentage of composite assets that
are bundled fee portfolios.
4.A.14 If a composite contains portfolios with
bundled fees, firms must disclose the various types
of fees that are included in the bundled fee.
4.A.15 When presenting gross-of-fees returns,
firms must disclose if any other fees are deducted in
addition to the direct trading expenses.
4.A.16 When presenting net-of-fees returns, firms
must disclose if any other fees are deducted in
addition to the investment management fee and
direct trading expenses.
4.A.18 Beginning 1 January 2006, firms must
disclose the use of a sub-advisor(s) and the periods a
sub-advisor(s) was used.
4.A.20 Firms must disclose the composite
description.
4.A.21 If a firm is redefined, the firm must disclose
the date and reason for the redefinition.
4.A.22 If a firm has redefined a composite, the
firm must disclose the date and nature of the change.
Changes to composites are not permitted to be
applied retroactively.
4.A.23 Firms must disclose any changes to the
name of a composite.
4.A.25 Firms must disclose if, prior to 1 January
2010, calendar month-end portfolio valuations or
valuations on the last business day of the month are
not used.
4.A.26 Firms must disclose which dispersion
measure is presented.
Disclosures - Recommendations
4.B.1 The portfolio valuation sources and methods used 4.A.17 Firms must disclose that additional

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by the firm. information regarding policies for calculating and
reporting returns is available upon request.
4.B.2 The calculation method used by the firm.
4.B.3 When gross-of-fee performance is presented, the 4.A.12 Firms must disclose the fee schedule
firm’s fee schedule(s) appropriate to the presentation. appropriate to the presentation.
4.B.4 When only net-of-fee performance is presented,
the average weighted management and other applicable
fees.
4.B.5 Any significant events within the firm (such as 4.A.19 Firms must disclose all significant events
ownership or personnel changes) that would help a which help a prospective client interpret the
prospective client interpret the performance record. performance record.
4.B.1 If a parent company contains multiple defined
firms, each firm within the parent company is
encouraged to disclose a list of the other firms
contained within the parent company.
4.B.2 Firms should disclose when a change in a
calculation methodology or valuation source results
in a material impact on the performance of a
composite return.
4.B.3 Firms that have been verified should add a
disclosure to their composite presentation stating
that the firm has been verified and clearly indicating
the periods the verification covers (if the composite
presentation includes results for periods that have
not been subject to firmwide verification.)
Presentations and Reporting - Requirements
5.A.1.a The following items must be reported for each 5.A.1 The following items must be reported for
composite presented: each composite presented:
At least five years of performance (or a record for the (a) At least 5 years performance (or a record
period since firm inception, if inception is less than five for the period since firm or composite inception, if
years) that is GIPS compliant. After presenting five years the firm or composite has been in existence less than
of performance, firms must present additional annual 5 years) that meet the requirements of the GIPS
performance up to ten years. (For example, after a firm Standards; after presenting 5 years of performance,
presents five years of compliant history, the firm must the firm must present additional annual performance
add an additional year of performance each year so that up to 10 years. (For example, after a firm presents 5
after five years of claiming compliance, the firm presents years of compliant history, the firm must add an
a 10-year performance record.) additional year of performance each year so that
after 5 years of claiming compliance, the firm
presents a 10 year performance record)

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5.A.1.b The following items must be reported: Firms 5.A.1.b Annual returns for all years
must present annual returns for all years.
5.A.1.c The following items must be reported: the 5.A.1.c The number of portfolios and amount of
number of portfolios and amount of assets in the assets in the composite, and either the percentage of
composite and the percentage of the firm’s total assets the total firm assets represented by the composite or
represented by the composite at the end of each period. the amount of total firm assets at the end of each
-- Combined With -- annual period. If the composite contains less than 5
4.A.2. Total firm assets for each period. portfolios, the number of portfolios is not required.
5.A.1.d The following items must be reported: A 5.A.1.d The following items must be reported: A
measure of the dispersion of individual component measure of dispersion of individual portfolio returns
portfolio returns around the aggregate composite return. for each annual period. If the composite contains
less than 5 portfolios for the full year, a measure of
dispersion is not required.
5.A.1.e. The standard Compliance Statement indicating 0.A.7 Once a firm has met all the required
firmwide compliance with GIPS. elements of the GIPS standards, the firm must use
the following compliance statement to indicate that
the firm is in compliance with the GIPS standards:
“[Insert name of firm] has prepared and presented
this report in compliance with the Global
Investment Performance Standards (GIPS®).”
5.A.1.f The following items must be reported: the 4.A.24 Firms must disclose the composite creation
composite creation date. date.
5.A.2. Firms may link non-GIPS-compliant performance 5.A.2 Firms may link non-GIPS compliant returns
to their compliant history so long as firms meet the to their compliant history, so long as firms meet the
disclosure requirements of Section 4 and no non- disclosure requirements for non-compliant
compliant performance is presented for periods after performance and only compliant returns are
January 1, presented for periods after 1 January 2000. (For
2000. (For example, a firm that has been in existence example, a firm that has been in existence since 1995
since 1990 that wants to present its entire performance that wants to present its entire performance history
history and claim compliance as of January 1, 2000, must and claim compliance beginning 1 January 2005,
present performance history that meets the requirements must present returns that meet the requirements of
of GIPS at least from January 1, 1995, and must meet the the GIPS Standards at least from 1 January 2000, and
disclosure requirements of Section 4 for any non- must meet the disclosure requirements for any non-
compliant history prior to January 1, 1995.) compliant history prior to 1 January 2000.)
5.A.3. Performance for periods of less than one year 5.A.3 Returns of portfolios and composites for
must not be annualized. periods of less than one year are not permitted to be
annualized.
5.A.4 Performance results of a past firm or affiliation can 5.A.4
only be linked to or used to represent the historical record (a) Performance track records of a past firm or

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1999 GIPS STANDARDS REVISED GIPS STANDARDS
of a new firm or new affiliation if affiliation must be linked to or used to represent the
• a change only in firm ownership or name occurs, or historical record of a new firm or new affiliation if:
• the firm has all of the supporting performance (i) Substantially all the investment decision-
records to calculate the performance, substantially all makers are employed by the new firm (i.e., research
the assets included in the composites transfer to the department, portfolio managers, and other relevant
new firm, and the investment decision-making staff),
process remains substantially unchanged. (ii) The staff and decision-making process
remain intact and independent within the new firm,
5.A.5. If a compliant firm acquires or is acquired by a and
non-compliant firm, the firms have one year to bring the (iii) The new firm has records that document
non-compliant firm’s acquired assets into compliance. and support the reported performance.
(b) The new firm must disclose that the
performance results from the past firm are linked to
the performance record of the new firm,
(c) In addition to the above four points, when
one firm joins an existing firm, performance of
composites from both firms must be linked to the
ongoing returns if substantially all the assets from
the past firm’s composite transfer to the new firm.
(d) If a compliant firm acquires or is acquired
by a non-compliant firm, the firms have one year to
bring the non-compliant assets into compliance.
5.A.6: If a composite is formed using single-asset carve- 5.A.5 Beginning 1 January 2006, if a composite
outs from multiple asset class composites, the includes or is formed using single asset class carve-
presentation must include the following: outs from multiple asset class portfolios, the
• a list of the underlying composites from which the presentation must include the percentage of the
carve-out was drawn, and composite that is composed of carve-outs
• the percentage of each composite the carve-out prospectively for each period.
represents.
5.A.7. The total return for the benchmark (or 5.A.6 The total return for the benchmark (or
benchmarks) that reflect the investment strategy or benchmarks) that reflects the investment strategy or
mandate represented by the composite must be presented mandate represented by the composite must be
for the same periods for which the composite return is presented for each annual period. If no benchmark
presented. If no benchmark is presented, an explanation is presented, the presentation must explain why no
of why no benchmark must be disclosed. If the firm benchmark is disclosed. If the firm changes the
changes the benchmark that is used for a given composite benchmark that is used for a given composite in the
in the performance presentation, the firm must disclose performance presentation, the firm must disclose
both the date and the reasons for the change. If a custom both the date and the reasons for the change. If a
benchmark or combination of multiple benchmarks is custom benchmark or combination of multiple

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1999 GIPS STANDARDS REVISED GIPS STANDARDS
used, the firm must describe the benchmark creation and benchmarks is used, the firm must describe the
re-balancing process. benchmark creation and re-balancing process.
Presentation and Reporting - Recommendations
5.B.1. The following items should be included in the 5.B.1 Firms are recommended to present the
composite presentation or disclosed as supplemental following items:
information:
(a) Composite returns gross of investment
management fees and administrative fees and before
(a) composite performance gross of investment
taxes (except for non-reclaimable withholding
management fees and custody fees and before taxes
taxes),
(except for non-reclaimable withholding taxes),
(b) cumulative returns for composite and benchmarks (b) Cumulative returns for composite and
for all periods, benchmarks for all periods,
(c) equal-weighted means and median returns for each
composite, (c) Equal-weighted mean and median returns for
each composite,
(d) volatility over time of the aggregate composite
return, and (d) Graphs and charts presenting specific
(e) inconsistencies among portfolios within a composite information required or recommended under the
in the use of exchange rates. GIPS Standards,
(e) Returns for quarterly and/or shorter time
periods,
(f) Annualized composite and benchmark returns
for periods greater than 12 months,
(g) Composite-level country and sector weightings.

5.B.2: Relevant risk measures—such as volatility, 5.B.2 Firms are recommended to present
tracking error, beta, modified duration, etc.—should be relevant composite-level risk measures, such as:
presented along with total return for both benchmarks and beta, tracking error, modified duration, information
composites. ratio, Sharpe ratio, Treynor Ratio, credit ratings,
value at risk (VaR), and volatility over time of the
composite and benchmark returns.
5.B.3 After presenting the required 5 years of
compliant historical performance, the firm is
encouraged to bring any remaining portion of their
historical track record into compliance with the
GIPS Standards. (This does not preclude the

14
1999 GIPS STANDARDS REVISED GIPS STANDARDS
requirement that the firm must add annual
performance to their track record on an on-going
basis to build a 10 year track record.)

Verification
2. Third-party verification brings credibility to the claim 0.B.2 Firms are encouraged to undertake the
of compliance and supports the overall guiding principles verification process, defined as the review of a
of full disclosure and fair representation of investment firm’s performance measurement processes and
performance. Verification is strongly encouraged and is procedures by an independent third-party verifier. A
expected to become mandatory (but no earlier than 2005). single verification report is issued in respect to the
Countries may require verification sooner through the whole firm; verification cannot be carried out for a
establishment of local standards. single composite. The primary purpose of
verification is to establish that a firm claiming
compliance with the GIPS Standards has adhered to
the Standards.

0.B.3 Firms that have been verified are


encouraged to add a disclosure to composite
presentations or advertisements stating that the firm
has been verified. Firms must disclose the periods
of verification if the composite presentation includes
results for periods that have not been subject to firm
wide verification. The verification disclosure
language should read:

“(Insert name of firm) has been verified for the


periods (insert dates) by (name of verifier). A copy
of the verification report is available upon request”.

III. Verification is strongly encouraged and is


expected to become mandatory at a future date. The
IPC will reevaluate all aspects of mandatory
verification by 2010 and provide the industry
sufficient time to implement any changes.

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