How to survive a GIPS verification Part 1: Setting up for success

Matt Deatherage
CFA, CPA, CIPM
July 23, 2021
15 min
How to survive a GIPS verification Part 1: Setting up for success

This article is part one of a three-part series on how to survive a GIPS verification. In this series we will discuss how to structure a successful verification, the initial requests made during a verification, and follow-up sample testing. Part one focuses on the approach we have seen firms successfully implement to get through a verification.

Step 1: Find a committed project manager

Probably the single most important thing necessary to get through a verification is having someone on your team that is committed to seeing the project through to the end. Verified firms come in all shapes and sizes. Therefore, there is not a one-size-fits all approach to managing a GIPS verification that works for every firm. Individuals tasked with overseeing verification projects naturally have other responsibilities, so finding time to focus on the verification can be difficult. But finding the right individual to manage the project can make all the difference.

Step 2: Educate your employees & stakeholders on GIPS and the verification process

Regardless of the size of your firm—and since GIPS compliance is achieved at the firm level—you will likely need input from a variety of people to complete your verification. Small and mid-size firms may not need to create a specific GIPS project team, but should still prepare to obtain input from different departments as verifiers regularly request information that requires input from others.

Educating your team about the importance of your firm’s GIPS compliance/verification and explaining how they can or will contribute to this effort is crucial. Getting their buy-in can make or break your timeline, as disengaged individuals are slow to respond to requests for information. We recommend making sure you get everyone on board. If Longs Peak is helping manage your verification, we can put together a training and deliver it to your team.

Step 3: Build your GIPS verification team

For larger firms, it may make sense to create a GIPS project team to help divide and conquer. Again, GIPS is achieved at the firm level, and therefore it will typically require input from various departments, including: performance, operations, client services, and trading, to name a few. Ideally, you’ll want at least one individual that clearly understands how your organization operates, the various departments that may need to be involved and where to access the documentation required.

The most efficient verification teams get together to discuss verifier requests and develop a plan for how the information is gathered, who is responsible for each type of request and who is ultimately responsible for sending the information back to the verifier.

We find that teams who meet regularly and communicate frequently are most successful at sticking to the timeline.  Having a designated project manager to act as the primary contact for the verification can simplify communication and ensure the requested information is organized. Ideally, this individual understands the fundamentals of GIPS – but don’t worry, if they don’t, Longs Peak can act as your GIPS guru. And, unlike your verifier, we’re not restricted by independence requirements so we can get as involved as you need.

Step 4: Create a verification project timeline

In our experience, most firms want their verification completed as soon as possible. Setting up a project timeline with specific milestones and clear deadlines will make this goal a reality. Verifications include numerous rounds of data requests to test different aspects of your firm’s GIPS policies and procedures. What’s great is you don’t have to do it yourself – your verifier or GIPS consultant can help you build out a timeline that works for your firm and will include all the critical objectives necessary. Check out this sample timeline to give you an idea of what’s typical.

When building out your timeline, the most important consideration is setting expectations for all parties involved and making sure they are on board with the project plan. Goals and deadlines are difficult, if not impossible to meet without communication. The firms that struggle the most are typically those that fail to transparently communicate expectations and receive buy-in for the project timeline from the start. Therefore, we strongly encourage you to involve all relevant parties (including your team, verifier and any third-party consultants) in setting project deadlines so everyone is aware of critical dates and milestones that need to be achieved.

Timelines should include goal dates for your firm as well as the verifier to hold everyone accountable to the ultimate goal: completing the verification. Tracking progress on the timeline will provide clarity on where the project is getting delayed and if the overall timeline is in jeopardy. Key stakeholders can use the timeline to evaluate the percentage of completion and can give your team a good sense of how close the project is to finish line.


Step 5: Set up recurring calls/meetings to stay on track

As simple as they are, setting up recurring meetings are a great tool to help keep the verification on track. These recurring calls can be internal to discuss the current requests and create action plans on collecting and delivering the needed data, or they can include your verifier to discuss progress, ask questions, and ensure they can correctly interpret the documentation provided. These meetings should have clear agendas to help the team stay on track with the timeline. Here’s a sample agenda we’ve used with our clients.

If nothing else, the recurring calls help build accountability – no one likes admitting they didn’t achieve what they agreed to since the prior meeting. The tighter the deadline, the more frequent these meetings should happen. These discussions can also be used to evaluate if you need to adjust the timeline from initial expectations.

Step 6: Organize data submissions

As mentioned, verifications typically have multiple rounds of requests for various types of testing (here’s a typical verification request for your perusal). Usually, the most efficient way to get through them is to submit everything from each request at once. This helps you stay organized by making sure all documents needed in a given round are provided. However, this is not always achievable and it may not be appropriate, especially in a time crunch or if just a handful of testing items are holding up the rest.

While potentially less desirable, a piecemeal approach at least keeps the sharing of documents moving and although some documents may still be pending, at least the items provided can be reviewed – getting your firm that much closer to the completion of the verification project.

If you are not able to submit everything from the data requests at once, we recommend approaching the verification requests either by the specific type of testing or type of document being requested. Approaching the verification in blocks of smaller requests will allow you to stay organized, reduce overwhelm, and keep the verification progressing. You can ask your verifier to organize their request in this format or if you work with Longs Peak, we can help you organize it in this fashion and help you get through the request at your own pace.

After data from the initial request is submitted to the verifier (details on initial data requests are discussed in more detail in part two of this three-part series) the verifier will then begin sending sample testing requests (the details of which are covered in part three of this three-part series). If this seems overwhelming, it doesn’t have to be. We literally started Longs Peak to make it easier for firms like yours get through this process.

If anything is not clear from a specific verification request or you are unsure if the documentation pulled is sufficient, give the verifier a call and talk through these issues. Open and ongoing communication will keep your verification on track – and help you avoid wasting time on something not needed.

Step 7: Schedule an onsite verification or extended virtual screenshare

One way to expedite the verification project (or to reignite a stalled project) is to conduct the verification onsite. Most GIPS verification firms are willing to travel to their client’s office to do on-site-testing. This is an efficient way to move through a verification as you will have the verifier’s undivided attention to specifically work through testing items and answer questions – plus, they might have your undivided attention too!

Even if an onsite is not feasible, setting up an extended virtual meeting with screensharing capabilities can help move through data with the verifier and address questions as they arise. Screenshare meetings will allow your team and the verifier to review documents together and talk through any questions on the spot. Feedback can be shared during these meetings to ensure what was provided is sufficient to complete a given testing request.

Conclusion

Regardless of your firm’s size or approach to the verification, ongoing communication between all parties involved is critical to efficiently get through a verification. Setting up a project plan and executing on that plan will help you get through the verification as quickly as possible. Seek help from your verifier as questions arise and if you still are struggling, reach out to an independent consultant like Longs Peak to help you get the project to the finish line.

At the end of the day, GIPS compliance is achieved at the firm level and will likely require contribution from a variety of individuals from your business. Getting buy-in from everyone involved is critical to making sure all parties are on board with the plan and understand the end goal.

For more information on data requests and verification testing, check out part two and three of this three-part series. You can email matt@longspeakadvisory.com or sean@longpseakadvisory.com with questions or reach out to us on our website if you need help getting through your verification project.

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ColoradoBiz Names Longs Peak’s Jocelyn Gilligan, CFA, CIPM as a GenZYZ Top Young Professional
Longs Peak is pleased to announce that Partner and Co-Founder, Jocelyn Gilligan has been named a GenXYZ Top Young Professional by ColoradoBiz Magazine. As ColoradoBiz states, “They’re uncommon achievers, whether as entrepreneurs, CEOs, nonprofit leaders, visionaries critical to their companies’ success or, in some cases, all of those roles. This year’s Top 25 Young Professionals figure to continue making a difference professionally and in their communities for years to come.”
March 14, 2023
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Longs Peak is pleased to announce that Partner and Co-Founder, Jocelyn Gilligan has been named a GenXYZ Top Young Professional by ColoradoBiz Magazine.

As ColoradoBiz states, “They’re uncommon achievers, whether as entrepreneurs, CEOs, nonprofit leaders, visionaries critical to their companies’ success or, in some cases, all of those roles. This year’s Top 25 Young Professionals figure to continue making a difference professionally and in their communities for years to come.”

Jocelyn grew up in Boulder, CO and graduated from the University of Colorado. She started her career at Ernst & Young in New York City where she worked on their Financial Services Transfer Pricing Team. She transferred with EY to their office in Shanghai and then eventually to Hong Kong. Jocelyn left EY as a Manager and relocated back to Colorado where she and her husband started a family. Soon thereafter, Jocelyn and Sean founded Longs Peak out of a small one-car garage in their home in Longmont, CO. Now running a thriving team of 14, Jocelyn has weathered the ups and downs of entrepreneurship. She credits a lot of their success to their amazing team and the community of entrepreneurs they live near and network with (Longs Peak is an active member of EO (Entrepreneurs Organization)).

Jocelyn is a voting member of the PTO at her children’s school and a member of Women in Investment Performance Measurement, a group recently founded to support women in the investment performance industry.

Please join us in celebrating this year’s ColoradoBiz Top Young Professionals nominees. You can view the complete list of nominees here

About ColoradoBiz’s Top 25 Young Professionals

The 13th annual Gen XYZ awards is open to those under 40 who live and work in Colorado — numbered in the hundreds, making for difficult decisions and conversations among judges, as always. Applications were judged by our editorial board based on career achievement, community engagement and their stories of how they got to where they are now.

About Longs Peak

Longs Peak is a purpose and values-driven company. It is our mission to make investment performance information more transparent and reliable—empowering investors to make better, more informed investment decisions.

At the onset, we were looking to help smaller investment managers by giving them access to professional performance experts and tools typically only available to very large firms. We know that our work enables emerging managers to compete with the big guys and helps facilitate their growth. We strive to be our clients’ most valued outsource partner and to be known for our exceptional client service. We know that providing exceptional client service means that we must first create a culture that lives by the ideals we are trying to create for our clients. A place where incredibly talented individuals are empowered to put their best work into the hands of clients that truly value what we do. As a firm, we recognize that our greatest asset is people – both those we work with and those we work for. We continue to evolve into something that represents the needs of both of these groups and hope someday a GIPS Report is provided to every prospective investor in the world.

SEC Clarifies Marketing Rule: Gross-of-Fee Returns Allowed Under Certain Conditions
The investment management industry has spent significant time grappling with the SEC’s Marketing Rule and the question of whether gross-of-fee returns can be presented without corresponding net-of-fee returns in certain cases. Many firms have invested resources in trying to allocate fees to individual securities and sectors in an effort to comply. However, the SEC has now issued two FAQs (March 19, 2025) that provide much appreciated clarity on extracted performance and portfolio characteristics. The key takeaway? It is possible to present gross-of-fee returns without net-of-fee returns—if certain conditions are met.
March 27, 2025
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The investment management industry has spent significant time grappling with the SEC’s Marketing Rule and the question of whether gross-of-fee returns can be presented without corresponding net-of-fee returns in certain cases. Many firms have invested resources in trying to allocate fees to individual securities and sectors in an effort to comply. However, the SEC has now issued two FAQs (March 19, 2025) that provide much appreciated clarity on extracted performance and portfolio characteristics. The key takeaway? It is possible to present gross-of-fee returns without net-of-fee returns—if certain conditions are met.

Extracted Performance: Gross Returns Can Stand Alone Under Specific Criteria

Investment advisers often present the performance of a single investment or a subset of a portfolio (“extracted performance”) in marketing materials. Historically, the SEC required both gross and net performance to be shown for such extracts. The new guidance provides a pathway for firms to display only gross-of-fee extracted performance, provided the following conditions are met:

  1. The extracted performance must be clearly identified as gross performance.
  2. The advertisement must also present the total portfolio’s gross and net performance in a manner consistent with SEC requirements.
  3. The total portfolio’s performance must be given at least equal prominence to, and facilitate comparison with, the extracted performance.
  4. The total portfolio’s performance must be calculated over a period that includes the entire period of the extracted performance.

If these conditions are satisfied, the SEC staff has indicated they will not recommend enforcement action, even if the extracted performance is presented without corresponding net returns. This is a notable shift, as it allows firms to avoid the complex and often impractical task of allocating fees at the investment or sector level.

Portfolio and Investment Characteristics: Net-of-Fee Not Always Required

Another common industry question has been whether certain portfolio or investment characteristics—such as yield, volatility, Sharpe ratio, sector returns, or attribution analysis—constitute “performance” under the marketing rule, and if so, whether they must be presented net of fees.

The SEC’s latest guidance acknowledges that calculating these characteristics net of fees can be difficult and, in some cases, may lead to misleading results. As a result, the staff has confirmed that firms may present gross characteristics alone, without net characteristics, if they meet the following criteria:

  1. The characteristic must be clearly identified as calculated without the deduction of fees and expenses.
  2. The advertisement must also present the total portfolio’s gross and net performance in a manner consistent with SEC requirements.
  3. The total portfolio’s performance must be given at least equal prominence to, and facilitate comparison with, the gross characteristic.
  4. The total portfolio’s performance must be calculated over a period that includes the entire period of the characteristic being presented.

As with extracted performance, these conditions help ensure that the presentation is not misleading, reducing the risk of enforcement action.

Bottom Line: A Practical Path Forward

This updated SEC guidance provides much-needed flexibility for investment managers, allowing for the presentation of gross-of-fee returns in a compliant manner. Firms that clearly disclose their approach and follow the specified conditions can reduce compliance burdens while still meeting investor protection standards. While this does not eliminate all complexities of the Marketing Rule, it does offer a practical solution that allows for more straightforward and meaningful performance reporting.

For firms navigating these changes, ensuring clear disclosures and maintaining compliance with the general prohibitions of the rule remains critical. Those who align their advertising materials with these guidelines can now confidently use gross-of-fee performance in a way that is both transparent and in compliance with regulatory requirements.

Questions?

If you have questions about calculating or presenting investment performance in a manner that complies with regulatory requirements or industry best practices, we would love to talk to you. Please feel free to email us at hello@longspeakadvisory.com.

New GIPS Standards Guidance for OCIOs: What You Need to Know
The Global Investment Performance Standards (GIPS®) have released a new Guidance Statement for OCIO Portfolios, bringing greater transparency and consistency to the way Outsourced Chief Investment Officers (OCIOs) report performance. This update is a significant milestone for firms managing OCIO Portfolios and asset owners looking to evaluate their OCIO providers.
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The Global Investment Performance Standards (GIPS®) have released a new Guidance Statement for OCIO Portfolios, bringing greater transparency and consistency to the way Outsourced Chief Investment Officers (OCIOs) report performance. This update is a significant milestone for firms managing OCIO Portfolios and asset owners looking to evaluate their OCIO providers.

What is an OCIO?

An Outsourced Chief Investment Officer (OCIO) is a third-party fiduciary that provides both strategic investment advice and investment management services to institutional investors such as pension funds, endowments, and foundations. Instead of building an in-house investment team, asset owners delegate investment decisions to an OCIO, which handles everything from strategic planning to portfolio management.

Who Does the New Guidance Apply To?

The Guidance Statement for OCIO Portfolios applies when a firm provides both:

  1. Strategic investment advice, including developing or assessing an asset owner’s strategic asset allocation and investment policy statement.
  2. Investment management services, such as portfolio construction, fund and manager selection, and ongoing management.

This ensures that firms managing OCIO Portfolios follow standardized performance reporting, making it easier for prospective clients to compare OCIO providers.

Who is Exempt from the OCIO Guidance?

The guidance does not apply in the following scenarios:

  • Investment management without strategic advice – If a firm only manages investments without advising on asset allocation or investment policy.
  • Strategic advice without investment management – If a firm provides recommendations but does not manage the portfolio.
  • Partial OCIO portfolios – If a firm only manages a portion of a portfolio, rather than the full OCIO mandate.
  • Retail client portfolios – The guidance is specific to institutional OCIO Portfolios and does not apply to retail investors including larger wealth management portfolios.

Key Change: Required OCIO Composites

Previously, OCIO firms had flexibility in defining their performance composites. Now, the GIPS Standards introduce Required OCIO Composites, which categorize portfolios based on strategic asset allocation.

Types of Required OCIO Composites

  1. Liability-Focused Composites – Designed for portfolios aiming to meet specific liability streams, such as corporate pensions.
  2. Total Return Composites – Focused on capital appreciation, commonly used by endowments and foundations.

Firms must classify OCIO Portfolios based on their strategic allocation, not short-term tactical shifts. This standardization enhances comparability across OCIO providers. The specific allocation ranges for the required composites are as follows:

Required OCIO Composites for OCIO Portfolios

Required OCIO Composites
Source: Guidance Statement for OCIO Portfolios

Performance Calculation & Reporting

To ensure transparency, firms must follow specific rules for return calculations and fee disclosures:

  • Time-weighted returns (TWR) are required, even for portfolios with private equity or real estate holdings.
  • Both gross and net-of-fee returns must be presented to clarify the true cost of OCIO management.
  • Fee schedule disclosures must include all investment management fees, including fees from proprietary funds and third-party placements.

Enhanced Transparency in GIPS Reports

The new guidance also requires OCIO firms to disclose additional portfolio details, such as:

  • Annual asset allocation breakdowns (e.g., growth vs. liability-hedging assets).
  • Private market investment and hedge fund exposures.
  • Portfolio characteristics, such as funding ratios and duration for liability-focused portfolios.

By providing these details, OCIO firms enable prospective clients to make better-informed decisions when selecting an investment partner.

When Do These Changes Take Effect?

The Guidance Statement for OCIO Portfolios is effective December 31, 2025. From this date forward, GIPS Reports for Required OCIO Composites must follow the new standards. However, firms are encouraged to adopt the guidance earlier to improve transparency and reporting consistency.

Why This Matters

With OCIO services growing in popularity, this new guidance ensures that firms adhere to best practices in performance reporting. By establishing clear rules for composite classification, return calculation, and fee disclosure, the guidance empowers asset owners to compare OCIO providers with confidence.

As the December 31, 2025 deadline approaches, OCIO firms should begin aligning their reporting practices with this new guidance to stay ahead of the curve.

Don’t miss CFA Institute’s webinar scheduled for this Thursday February 6, 2025 to hear more on this guidance statement.

Questions?

If you have questions about the Guidance Statement for OCIO Portfolios or the Standards in general, we would love to talk to you. Longs Peak’s professionals have extensive experience helping firms become GIPS compliant as well as helping firms maintain their compliance with the GIPS Standards on an ongoing basis. Please feel free to email us at hello@longspeakadvisory.com.