GIPS Compliance FAQs

Matt Deatherage, CFA, CIPM
Partner
December 16, 2020
15 min
GIPS Compliance FAQs

Our team has assisted hundreds of firms and asset owners with their GIPS compliance. Over the years, there are some questions that we see quite frequently. This article lists each of these GIPS FAQs and provides some clarification to help navigate the GIPS standards.

Question 1: What are the requirements for distributing GIPS Reports?

The GIPS standards require that all qualified prospective clients and prospective investors (as defined in your GIPS Policies and Procedures) receive relevant GIPS Composite Reports or GIPS Pooled Fund Reports (“GIPS Reports”) once they initially meet this definition. If the prospect still meets this definition 12 months after they initially received the GIPS Report, they are required to receive an updated version of that Report at that time.

Prospective clients include individuals and institutions that are considering opening a segregated account that will be managed in line with any composite strategies. Prospective investors include individuals and institutions that are interested in investing in pooled funds. Additionally, if composite strategies or pooled funds are offered through intermediaries, these intermediaries also must be treated as prospects and must receive the GIPS Reports each year. This includes third party advisors, wrap sponsors, and institutional databases that are used to present strategy information. Responses to Requests for Proposal (“RFPs”) must also include a GIPS Report for any strategies or pooled funds discussed in the RFP.

To clarify, regarding pooled funds, providing the GIPS Report is only required if the fund is a “Limited Distribution Pooled Fund”; “Broad Distribution Pooled Funds” (most mutual funds in the US) are exempt from this requirement. For more information on distinguishing between broad and limited distribution pooled funds, please see question 9 below or check out How to Update Your GIPS Reports for the 2020 GIPS Standards.

Please keep in mind that the requirement to distribute GIPS Reports is relevant to any composite or limited distribution pooled fund a prospect may be interested in, even if they are considered “non-marketed” strategies. In other words, you must always distribute a GIPS Report to a prospect for the strategies they are interested in, even if the composite is not marketed, and even if the prospect doesn’t ask about GIPS or request the report.

Also, the 2020 GIPS standards now require proof that this distribution requirement was met. To do so, distribution now needs to be tracked. There is no required format, but most often this is either done in a CRM system or in Excel. The format must be such that it can be provided upon request to verifiers and/or regulators who wish to see evidence of compliance with this requirement. These internal logs should document who received the GIPS Report, when they received the GIPS Report, which GIPS Report they received, and the form of delivery.

Question 2: To comply with the GIPS standards, are we required to market all composite results and how can performance be presented outside of GIPS Reports?

GIPS Reports are the only required marketing document that must be created and maintained for composites and limited distribution pooled funds to comply with the GIPS standards. Outside of the distribution requirements to prospects (see Question 1), you are not required to present the performance of any composite. Most firms just have a few composites they actively market while the other composites exist primarily to meet the requirement of having every discretionary, fee-paying portfolio in at least one composite. What you choose to present outside of your GIPS Reports is outside the scope of GIPS and can include anything meaningful to your organization and strategies as long as it does not violate any local regulatory requirements, does not conflict with the information presented in the GIPS Report, and is not considered false or misleading.

When advertising, mentioning GIPS is optional. If mentioning GIPS, then either a GIPS Report must be included or the GIPS Advertising Guidelines can be followed instead. The GIPS Advertising Guidelines offer an abbreviated way to mention GIPS compliance without including a full GIPS Report. A checklist of the required advertising disclosures can be downloaded here: 2020 GIPS Advertising Disclosure Checklist.

Since the advertising provisions are optional, mentioning GIPS or the claim of compliance is not required in any documents outside of the GIPS Reports if not desired. Anyone claiming compliance with GIPS may maintain their current procedures for internal client reporting and other marketing documents, as long as there is consistency with GIPS in their strategies and how they hold themselves out to the public.

Question 3: What is the scope of a GIPS verification and are we required to be verified?

GIPS verification provides assurance on whether GIPS 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. Compliance with all applicable requirements of the GIPS standards, even those beyond what is specified in the verification procedures, is required to claim compliance. Therefore, verification does not guarantee the accuracy of any specific performance presentation or set of statistics, but rather opines on the existence of a framework put in place to consistently apply the requirements of the GIPS standards.

During a verification, the selected verifier will use the GIPS policies and procedures to test various aspects of the established framework for GIPS compliance. Undergoing a verification is not a requirement to be able to claim compliance with GIPS, but it is a recommendation set forth by CFA Institute.

Question 4: When should composites utilize minimum asset levels and significant cash flow policies?

The GIPS Standards allow for the creation of composite-specific rules, such as minimum asset levels and significant cash flow policies. The purpose of both policies is to help ensure the composite results are a meaningful representation of the portfolio manager’s discretionary management.

Minimum asset levels ensure that small portfolios that may not be diversified the same as larger portfolios are excluded from composites; significant cash flow policies temporarily remove portfolios from composites for periods where the client is making contributions or withdrawals that are large enough to disrupt the management of the portfolio. Both policies require pre-determined thresholds to be documented in the GIPS policies and procedures document.

For example, if $100,000 is the minimum size needed to fully implement the composite’s strategy, a minimum asset level could be set at $100,000, which would then trigger the exclusion of all portfolios with assets less than $100,000. If a significant cash flow policy has a threshold of 20%, this means that any period where a portfolio experiences a contribution or withdrawal of 20% or more of the portfolio’s fair value, the portfolio is temporarily excluded from the composite for that performance period. Detailed rules must be documented to specify exactly how long the portfolio remains excluded and should be based on the typical amount of time needed to bring the portfolio back in line with the composite’s strategy.

Since these policies are composite-specific, each composite can have different thresholds. You may also elect to set up these policies for some, but not all composites. The most important factor in determining if these policies should be implemented for a composite is whether asset amounts are important to implementation of the strategy and if big external cash flows materially disrupt the investment process. If the strategy is very liquid then these policies may not be necessary. Also, if the composite is large in terms of number of portfolios, a little dispersion caused by small portfolios or portfolios experiencing significant cash flows may have only a very minor impact on the composite results. If the impact is small, the burden of administering the policy may not be worth the effort.

Another important consideration is whether adding these policies to a composite could create performance breaks in the future. If a composite is very small in terms of number of portfolios, these policies should not be utilized unless they are essential to create meaningful composite results. If utilizing these policies creates a scenario where all the composite’s portfolios are excluded for the same period, there will be a break in the performance track record that cannot be linked.

Question 5: When are we required to file the GIPS Compliance Notification form?

GIPS compliant firms and asset owners are required to notify CFA Institute of their claim of compliance once they initially become compliant and once a year thereafter (before June 30th of each calendar year). We recommend setting reminders on your internal compliance calendar to make sure this requirement is not missed. Firms and asset owners are allowed to complete this form each year between January 1st and June 30th with information based on December 31st of the prior year. Once the annual form is filed, save the email confirmation from CFA Institute. Firms and asset owners that are verified are required to provide this confirmation to their verifier to support that this requirement was met.

Question 6: How do we determine the discretionary status of a portfolio for GIPS purposes?

Not all portfolios with discretionary contracts are considered discretionary for GIPS purposes. Portfolios with material, client-mandated restrictions may be deemed non-discretionary if they are not a meaningful representation of the portfolio manager’s discretionary management. Documentation of the definition of discretion must be maintained in your GIPS policies and procedures to ensure clear criteria can be consistently applied when determining the discretionary status of each portfolio.

The most common criteria documented that trigger portfolios to be deemed non-discretionary for GIPS include:

  • Investment restrictions that affect over X% of portfolio assets
  • Portfolio manager must obtain client approval prior to trade execution
  • Tax sensitivity that restricts trading or requires the harvesting of gains/losses
  • Client directed use of margin
  • Liquidity needs and/or recurring contributions or distributions
  • Restrictions on credit ratings or duration

Please note that this is not an all-inclusive list, nor is it a list of required criteria. We recommend documenting examples that are meaningful to your organization and the types of strategies managed.

Utilizing percentage thresholds can help ensure the criteria is applied consistently. For example, if you manage clients with legacy positions (and these positions cannot be segregated from the strategy for performance purposes) you can set a percentage threshold to indicate when the size of the position is large enough to require exclusion from the composite. Specifically, this means that if the threshold is set at 10%, portfolios with restricted positions totaling less than 10% will be included in the composite while portfolios with restricted positions totaling 10% or more will be excluded from the composite. Using a threshold rather than excluding all portfolios with restrictions in any amount helps reduce the number of non-discretionary portfolios and allows as many portfolios to be included in composites as possible. Again, applying a clear threshold helps ensure there is consistency in the determination of discretionary status.

Question 7: Before we change our portfolio accounting system, what GIPS questions should we consider?

Because the cost of portfolio accounting systems can be significant, it is common to re-evaluate options and occasionally switch systems when feasible to do so. When considering a new system, it is critical that you confirm that the new system’s calculation methodology meets the minimum requirements set forth in the GIPS standards. If considering a newer system that is not well known, it is best practice to confirm that the system has current users that are GIPS compliant and that these users have had their GIPS compliance verified by a reputable GIPS verification firm. Confirming this can provide added comfort that the calculation methodology has been tested.

Once you know that the system meets the requirements of the GIPS standards as well as other general accounting and reporting needs, it is important to plan the logistics of the conversion. Part of this includes ensuring that the historical performance track record is maintained and can be adequately supported to meet the books and records requirements of the GIPS standards.

Standards related to books and records require the ability to support everything reported in your GIPS Reports. Portfolio-level holdings, transactions, prices, etc. should be maintained to be able to reproduce or prove out any statistics requested by a verifier or regulator. If historical results are hardcoded in the new system without portfolio-level details, it is important to ensure that transactions, holdings, prices, etc. are still retrievable in the prior system or from the custodian.

If historical transaction details will be added to the new system, it is important to consider if the historical portfolio and composite results will be hardcoded from the old system or recalculated in the new system. This is because the new system may have a different calculation methodology than the old system (e.g., daily valuation instead of only revaluing for large cash flows) and the historical results may change when recalculated in the new system. The GIPS standards do not allow for a retroactive change to calculation methodology so this new method should only be applied prospectively.

Additionally, we strongly recommend having an overlapping period where both systems run concurrently. Especially when historical periods are recalculated in the new system, it often takes time to get this historical data reconciled to match the old system.

The final consideration includes updating GIPS policies and procedures documents to reflect changes. Documentation of the portfolio accounting change should be made with details describing any changes to methodology. The date of the conversion must be clearly documented with a clear description of what the methodology was before that date and what it will be going forward.

Question 8: What is required when a making a benchmark change?

The GIPS Standards allow changes to the benchmarks used in the GIPS Reports if a different benchmark is considered a more meaningful comparison to the strategy. When a benchmark change is made, benchmark(s) can either be changed prospectively or retroactively.

Prospective benchmark changes are typically made when the composite or pooled fund strategy has shifted and a different benchmark will be a more meaningful comparison for the strategy going forward, while the old benchmark is still the best benchmark for the older periods. Retroactive benchmark changes are typically made when a new benchmark is determined to be a more meaningful comparison for the entire history of the strategy.

Both prospective and retroactive benchmark changes require disclosure in the GIPS Report that had the change. Prospective changes must be disclosed for as long as the original benchmark remains part of the presented information, while the disclosure of a retroactive change may be removed after a one-year period. For example disclosure language see: 2020 GIPS Report Disclosure Checklist.

Question 9: How do we determine if our pooled funds are considered limited or broad distribution and what is different about applying the GIPS standards in each case?

New to the 2020 edition of the GIPS Standards is requirements specifically addressing the presentation of performance to prospective investors in pooled funds. Pooled funds now must be classified as either broad or limited distribution. The best approach to determine this classification is to look at the way these funds are discussed with prospective investors.

If the sales communications are done exclusively in a private, one-on-one setting, the fund is likely a limited distribution pooled fund (e.g., a pooled vehicle set up as a limited partnership). If the fund is offered to prospective investors publicly (e.g., a mutual fund), the fund is likely a broad distribution pooled fund. The determination on whether your pooled fund is a broad or limited distribution fund must be done at the total fund, not share class, level.

Anyone claiming GIPS compliance is required to maintain a list of both types of funds and must include descriptions for the limited distribution funds (descriptions are not required for broad distribution pooled funds). GIPS Reports must be provided to all prospective investors of limited distribution pooled funds, but this is not required for prospective investors in broad distribution pooled funds.

The GIPS Report can be specific to the limited distribution pooled fund itself or it can be for the composite in which the pooled fund is included. Whether providing a GIPS Pooled Fund Report or a GIPS Composite Report, the detailed fees of the fund including the fund’s total expense ratio must be included. For more information on this requirement check out How to Update Your GIPS Reports for the 2020 GIPS Standards.

Regardless of the type of pooled fund, if it meets the definition of an existing composite (i.e., a composite created for segregated accounts), the fund must be included in the composite. If no composite exists matching the strategy of the fund, there is no longer a requirement to include the fund in a composite (i.e., beginning in 2020 creating composites for pooled funds is no longer required if the strategy is only offered to prospective pooled fund investors).

Question 10: When do the GIPS standards allow the calculation of money-weighted returns instead of time-weighted returns?

The use of money-weighted returns (“MWR”) in GIPS Reports instead of time-weighted returns (“TWR”) has broadened under the 2020 edition of the GIPS standards. MWRs may be shown in addition to TWRs if desired; however, if replacing TWR with MWR, certain criteria must be met. Specifically, the manager must control the timing and amount of the external cash flows for the strategy and must also meet at least one of the following criteria:

  • The investment vehicle must be closed-end
  • The investment vehicle must have a fixed-life
  • The investment vehicle must have fixed commitments, or
  • A significant portion of the assets in the strategy must be illiquid investments

If a strategy meets these requirements, then the option to present only MWR in the GIPS Report is available, but not required (TWR can still be used if preferred). When switching the returns from TWR to MWR (or vice versa) in the GIPS Report, the change must be disclosed. Switching methodologies should be avoided unless absolutely necessary as one method should be selected as the most meaningful representation of the strategy’s performance. Examples of disclosure language are available here: 2020 GIPS Report Disclosure Checklist.

Questions?

If you have questions contact us or email Matt Deatherage at matt@longspeakadvisory.com.

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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:

  1. Define the firm and scope the universe of portfolios
  2. Build policies and procedures
  3. Construct composites and calculate performance
  4. 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:

  1. Identify every portfolio that meets the composite definition
  2. Determine the correct dates each portfolio should be in and out of the composite
  3. Asset-weight the portfolio-level monthly returns to produce composite-level performance
  4. 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.