GIPS Checklist
Definition of Firm
- The firm must be defined as an investment firm, subsidiary
or distinct business entity (refer to p. 10 of GIPS manual
for definition)
- GIPS standards must be applied on a firm-wide basis (the
firm is compliant, not the composites)
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Definition of Total Firm Assets
- Includes all discretionary, non-discretionary assets, fee-paying
and non-fee-paying accounts
- Excludes assets underlying overlay investment strategies
unless the firm manages the underlying assets
- Excludes assets assigned to sub-advisors unless the sub-advisor
has discretion over the underlying assets
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Effective Dates for GIPS Compliance
- January 1, 1993 for all fee-paying, discretionary, non-taxable
accounts invested in US and/or Canadian assets
- January 1, 1994 for all fee-paying, discretionary accounts
invested in non-US and/or non-Canadian assets
- July 1, 1995 for all fee-paying, discretionary, wrap-fee
accounts
- January 1, 1997 for the inclusion of accrued income for
fixed income
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Retroactive GIPS Compliance
- Firms must report at least 5 years of performance or since
firm’s inception, if less than 5 years, and subsequently
accumulate performance up to a minimum of 10 years
- GIPS compliance standards are in force as of January 1,
2006
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Future GIPS Requirements
- Refer to p. 12 of GIPS manual for requirements and dates
- Future requirements may be implemented earlier at the discretion
of the firm
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Claim of Compliance
- Firms must comply with all composite, calculation, disclosure
and presentation requirements
- Firms must use the standard GIPS compliance statement (since
compliance refers to the firm, firms cannot claim that calculation
methodologies are in compliance with GIPS)
- Compliant presentations not older than 12 months must be
made available to all potential clients. Presentations
apply to composite-specific presentations as well
- If local or country standards conflict with the GIPS, firms
must conform to the local and/or country standards and disclose
the fact
- Firms may link non-compliant performance prior to January
1, 2000 to compliant performance
- GIPS CVG performance may be shown up to January 1, 2006
- When presenting a joint marketing presentation, the compliant
firm must be clearly identified
- If a composite presentation includes results from periods
that have not been verified, this must be disclosed
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| GIPS
Checklist, cont'd. . . |