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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)

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

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

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

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

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
GIPS Checklist, cont'd. . .
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