How to Update your GIPS Policies & Procedures for GIPS 2020

Sean P. Gilligan, CFA, CPA, CIPM
Managing Partner
May 20, 2020
15 min
How to Update your GIPS Policies & Procedures for GIPS 2020

If you are an investment firm or asset owner that complieswith the GIPS standards you are required to make some modifications to yourGIPS policies and procedures (“P&P”) to address changes made to the 2020edition of the Standards. The extent of these updates depends on:

  1. whetheryour organization plans to adopt any new optional policies,
  2. whetheryou have pooled funds to add to the current list of composites, or
  3. ifyour organization plans to change any calculation methodologies now allowedunder the new standards.

Like other GIPS requirements, consistent application andadequate documentation are critical to ensuring these updates and changes areapplied correctly and consistently.

GIPS 2020: Minimum Requirements for all GIPSCompliant Organizations

There are some required GIPS policies & procedure updatesthat will impact all organizations claiming compliance. At a minimum, all firmsand asset owners must address the following in their P&P:

Terminology

What was previously called “Compliant Presentations” are nowcalled “GIPS Reports” in the 2020 GIPS standards. Likely, the term “CompliantPresentations” is used throughout your P&P, which needs to be replaced with“GIPS Reports” to be in sync with the language of the updated standards.

Demonstrate that GIPS Reports are Distributed

It has always been a good idea to maintain a log documentingthe distribution of GIPS Reports to help support that your firm met therequirement of providing them to prospective clients; however, it was notpreviously required. The 2020 edition of the GIPS standards now requires firmsto demonstrate how it made every reasonable effort to provide a GIPS Report toprospective clients that are required to receive one.

The most common way to do this is by maintaining a log of thedistribution in a spreadsheet or by noting the distribution in your firm’s CRMsystem. If noting distribution in your CRM, it is important to populate this ina way that can easily be extracted into a report. Your GIPS verifier is nowrequired to test this so you will need to be able to produce a report demonstratingthat your firm is distributing GIPS Reports to prospective clients.

In addition, you must now update your P&P to document theprocess for how this is maintained. Although each firm will need to documentthis differently to accurately describe their process (i.e., the system inwhich it is maintained and who is responsible for maintaining it), below is anexample of how this may be documented:

Each time a GIPS Report is distributed, the firm’s SalesAssociate is responsible for logging the distribution on the firm’s CRM system.This documentation will include who received the GIPS Report, the version ofthe GIPS Report they received, the method of delivery, and the date it wasdelivered. This information may be extracted from the CRM system by the SalesAssociate if requested by a verifier, regulator, or if needed internally.

Error Correction Procedures

In the 2010 edition of the GIPS standards, if a material errorwas discovered in a compliant presentation, correction and redistribution wasrequired with a disclosure of the change to “all prospective clients and otherparties that received the erroneous compliant presentation.” In addition tothese, the 2020 GIPS standards specifically call out providing corrected GIPSReports to your current GIPS verifier as well as any former verifier or currentclient that received the GIPS Report containing the material error.

Currently, most firms’ policies relating to material errors arelikely limited to the action they take to redistribute to current prospectiveclients. We recommend updating this language to specifically address the needto provide the corrected presentation to verifiers and clients who received theerroneous presentation as well. An example of how this may be documented isprovided below:

Our firm willdetermine an identified error is material if the error exceeds the materialitythresholds stated in the Error Correction Policy: Materiality Grid. If thisoccurs, we will correct all affected GIPS Reports, include a disclosure of thechange, and make every reasonable effort to provide a corrected GIPS Report to:

  • Prospective clients that received the GIPS Reportthat had the material error;
    • Clients and any former verifiers that received theGIPS Report that had the material error; and
    • Current GIPS verifier.

Verifier Independence

Verifiers are prohibited from testing their own work and,therefore, cannot help their clients by writing policies, calculatingperformance, creating GIPS Reports, etc. To help ensure this independence ismaintained, firms that are verified are now required to gain an understandingof their verifier’s policies for maintaining independence and to consider theirverifier’s assessment of independence to ensure there are no conflicts.

To comply with this, firms must request that their verifierprovide documentation describing the measures they take during the verificationprocess to ensure independence is maintained. The procedures for requesting andassessing this needs to be described in the firm’s GIPS policies &procedures. Below is an example of what this might look like:

Our firm has engaged XYZ Verification Firm as anindependent third-party verification firm to verify our claim ofcompliance. Each year, prior to the start of the annual verification, werequest the independence policy statement from the verification firm.  If there are no changes from the prior year,this confirmation is requested in writing. Any potential threats to independence, either in fact or in appearance,are discussed with the verifier to resolve immediately.

GIPS Report Updates

We will discuss all the changes relating to GIPS Reports in aseparate blog; however, some of those changes will require updates to yourfirm’s GIPS policies and procedures, which we do want to discuss here.Presenting annual internal dispersion and three-year annualized ex poststandard deviation is not new; however, it is new that firms are required todisclose whether gross-of-fee or net-of-fee returns are used in thesecalculations. We recommend adding language to your P&P that makes it clearwhether you will use gross-of-fee or net-of-fee returns. Including this in yourP&P will help you ensure the calculation is consistent with the disclosureyou will be adding to your GIPS Reports. An example of how this could be wordedis as follows:

Composite internal dispersion is measured using theasset-weighted standard deviation of annual gross-of-fee returns of thoseportfolios included in the composite for the full year. The three-yearannualized ex post standard deviation measures the variability of the compositegross-of-fee returns and benchmark returns over the preceding 36-month period.

While either gross-of-fee or net-of-fee returns areacceptable, at Longs Peak we generally recommend that our clients usegross-of-fee returns so the presented volatility relates specifically to the implementationof the strategy and is not affected by management fees (which may differ byaccount, be paid at different times, etc).

Additionally, there is a new requirement to update GIPSReports with the prior year’s information within 12 months of the periodending. In other words, statistics for the period ending December 31, 2020 mustbe added to your GIPS Reports by December 31, 2021.That will be plenty of timefor most firms, but to ensure this is done, we recommend adding a procedure toyour P&P document simply explaining that the reports must be updated within12 months after the end of each annual period.

GIPS 2020: Changes for Firms with Pooled Funds

Firms that have pooled funds willhave a few additional changes to make to their GIPS policies & procedures.

Terminology

Most firms will have language intheir P&P referring to “prospective clients.” In the 2020 GIPS standards,the term prospective client refers specifically to a prospective separateaccount investor while the term “prospective investor” is used when referringto a prospective pooled fund investor. Firms need to review their P&P language and make updates to defineboth terms and ensure they are using the appropriate term depending on thecontext of what is being described.

List of Pooled Funds

Firms have always been required to maintain a list ofcomposite descriptions, but now the same is needed for each pooled fund thefirm manages. For each limited distribution pooled fund, a description needs tobe included (similar to what was done historically for composites). Broaddistribution pooled funds need to be listed, but no description is required.

If you are unsure whether a pooled fund is considered broaddistribution or limited, broad distribution pooled funds are defined in theglossary of the 2020 GIPS standards as “A pooled fund that is regulated under aframework that would permit the general public to purchase or hold the pooledfund’s shares and is not exclusively offered in one-on-one presentations.Limited distribution pooled funds are simply defined as any pooled fund thatdoes not meet the definition of a broad distribution pooled fund.

Pooled Fund Inception Date

Pooled fund performance must be reported back to the pooledfund’s inception date. How the inception date was determined must be documentedin the firm’s GIPS policies & procedures. Inception date could be based onwhen investment management fees are first charged, when the firstinvestment-related cash flow takes place, when the first capital call is made,or when committed capital is closed and legally binding. Whatever criteria isused to determine the inception date must be clearly described in the P&Pto ensure an appropriate inception date is used for each pooled fund managed bythe firm.

Error Correction Thresholds

If language used to document error correction materialitythresholds is specific to composites, this will need to be modified toincorporate thresholds for statistics reported in GIPS Pooled Fund Reports aswell. If the same thresholds are appropriate for both composites and pooledfunds (e.g. composite and pooled fund performance can have the same thresholdand composite and pooled fund assets can have the same threshold) then this maybe as simple as changing “Composite” to “Composite/Pooled Fund” throughout thissection.

Additionally, if your firm is now presenting money-weightedreturns and other related multiples for closed-end funds, you will need to addthresholds to your policy for these statistics as well.

Changes for other Optional Policies

The 2020 GIPS standards offer some more flexibility to ensure theyare as meaningful and useful as possible to all types of investment firms andasset owners. If any of these policies are utilized, additional changes will berequired to describe their use in your firm’s GIPS policies & procedures.Examples of these optional policies include, but are not limited to:

Carve-Outs

If a firm decides to utilize carve-outs with allocated cash,the new carve-out composite will need to be documented in the current list ofcomposites. In addition, the firm will need to implement policies andprocedures as to how they allocate cash, how they identify appropriate assetbuckets to carve-out from existing accounts, which accounts have asset groupsthat need to be carved-out to meet the new composite definition, and documentother composite related policies applied to the carve-out composite.

Portability

Historically, GIPS compliant firms meeting the portabilityrequirements were required to link the historical performance record to theongoing performance. The 2020 GIPS standards change this to make linkingoptional. When portable track records exist, firms need to document in theirP&P 1) whether the historical track record meets the GIPS portabilityrequirements and 2) whether they are electing to link the historicalperformance record or choosing to not link it.

Estimated Transaction Costs

The GIPS standards define “gross-of-fees” as the return oninvestments reduced by transaction costs. Historically, firms complying withthe GIPS standards were prohibited from estimating transaction costs; the useof actual transaction costs was required. The 2020 GIPS standards nowallow estimated transaction costs to be used in cases where actual transactioncosts are not known.

Using actual transaction costs is straightforward fortraditional portfolios that pay transaction costs in the form of commissions oneach trade. The issue most commonly arises with wrap accounts that paytransaction costs as part of a bundled fee.

Historically, firms were not able to present returnsgross-of-fees for their composites containing wrap accounts because they wereunable to determine the actual transaction costs. Most firms instead present“pure gross” returns, which are gross of the entire wrap fee and are requiredto be labelled as supplemental information.

Allowing estimated transaction costs will give firms managingwrap accounts the option to estimate the portion of the wrap fee that is for transactioncosts and reduce returns by this estimated figure.

If estimated transaction costs are utilized, the firm mustdisclose in their GIPS Reports how these estimated transaction costs aredetermined. Similarly, the process used to determine the estimated transactioncosts and the methodology utilized to reduce the returns by the estimatedtransaction costs needs to be documented in the firm’s P&P.

Model Management Fees

Previously, GIPS compliant firms using model investmentmanagement fees (rather than actual fees) to determine net-of-fee results wererequired to use the highest investment management fee. This was generallyinterpreted as the highest fee from the composite’s fee schedule or the highestfee-paying portfolio in the composite, whichever was higher. In the 2020 GIPSstandards, firms using model management fees are required to use a fee that is“appropriate” to the prospective client. While the model fee doesn’t specificallyhave to be the highest fee, the resulting returns still need to be equal to orlower than the results that would be calculated if actual management fees wereused.

If your P&P already describes using the highest managementfee and you will continue to use the highest fee then no change is needed. Ifyou will implement a new process other than highest fee, then it is importantto update your P&P to describe how the model fee will be determined andapplied. This description needs to include how you will confirm that thenet-of-fee returns using the model fee are not higher than they would be if theactual investment management fees were used.

Presenting Advisory-Only Assets

Firms that have Unified Managed Accounts (“UMA Accounts”) orother similar arrangements where they are simply providing a model to beimplemented by another party generally are not able to include these accountsin their total firm assets. These accounts are considered “advisory-only” becausethe manager is only providing the model and has no responsibility to implementthe strategy or monitor the portfolios on an ongoing basis.

This type of arrangement has become increasingly popular overthe last decade. Given the popularity of these relationships, many firms nowhave a large amount of advisory-only assets that they would like to report.Because of this demand, the 2020 GIPS standards have provided guidanceoutlining the proper way for firms to present these assets separate from theirtotal firm assets. Firms electing to present these assets must make it clearhow they intend to report them in their GIPS Reports.

Historically, many firms documented in their P&P somethinglike, “all accounts deemed to be advisory-only, hypothetical, or model innature are excluded from total firm assets” to make it clear that they were notincluding anything in total firm assets that was prohibited. Firms now electingto separately present advisory-only assets must add an additional statementdescribing how they will be presented. For example, “Some of the firm’sstrategies are offered through UMA platforms on an advisory-only basis. Theseassets are presented separately from the firm’s composite assets and total firmassets and will be labelled ‘Advisory-Only Assets’.”

Presenting Money-Weighted Returns

Historically, time-weighted returns were required with twospecific asset class exceptions: Private Equity and Real Estate (when RealEstate was managed in a Private Equity-like fund). The 2020 GIPS standards havenow removed the asset-class specific requirements. Instead, firms may nowpresent money-weighted returns for any asset class as long as the firm hascontrol over the external cash flows and the composite or pooled fund has atleast one of the following characteristics:

  • Closed-end
  • Fixed life
  • Fixed commitment
  • Illiquid investments are significant portion ofstrategy.

For firms meeting this criteria and electing to present money-weightedreturns, the P&P must be updated to 1) note that the criteria was met, 2)indicate the election to present money-weighted returns, and 3) outline themethodology utilized to calculate the money-weighted return and other relatedmultiples that must be presented in conjunction with the money-weighted return.

Other Considerations for GIPS Policies &Procedures

When going through your firm’s GIPS policies & procedures to make the required changes for the 2020 GIPS standards, this is a great opportunity to review the document as a whole to ensure everything is still relevant, applicable and accurate. One of the most common deficiencies regulators write in examinations is that policy and procedure documents do not reflect actual practices of the firm. We recommend a comprehensive review be conducted annually. Check out GIPS Compliance Actions for the New Year for a step-by-step guide to this review .

Questions?

If you have a situation that we didn’t cover here that isspecific to your firm or for more information on GIPS Policies and Procedures,the changes to the GIPS standards for 2020, or GIPS compliance in general,contact Matt Deatherage at matt@longspeakadvisory.comor Sean Gilligan at sean@longspeakadvisory.com.

Recommended Post

View All Articles

Key Takeaways from the 29th Annual GIPS® Standards Conference in Phoenix

The 29th Annual Global Investment Performance Standards (GIPS®) Conference was held November 11–12, 2025, at the Sheraton Grand at Wild Horse Pass in Phoenix, Arizona—a beautiful desert resort and an ideal setting for two days of discussions on performance reporting, regulatory expectations, and practical implementation challenges. With no updates released to the GIPS standards this year, much of the content focused on application, interpretation, and the broader reporting and regulatory environment that surrounds the standards.

One of the few topics directly tied to GIPS compliance with a near-term impact relates to OCIO portfolios. Beginning with performance presentations that include periods through December 31, 2025, GIPS compliant firms with OCIO composites must present performance following a newly prescribed, standardized format. We published a high-level overview of these requirements previously.

The conference also covered related topics such as the SEC Marketing Rule, private fund reporting expectations, SEC exam trends, ethical challenges, and methodology consistency. Below are the themes and observations most relevant for firms today.

Are Changes Coming to the GIPS Standards in 2030?

Speakers emphasized that while no new GIPS standards updates were introduced this year, expectations for consistent, well-documented implementation continue to rise. Many attendee questions highlighted that challenges often stem more from inconsistent application or interpretation than from unclear requirements.

Several audience members also asked whether a “GIPS 2030” rewrite might be coming, similar to the major updates in 2010 and 2020. The CFA Institute and GIPS Technical Committee noted that:

    ·   No new version of the standards is currently in development,

     ·   A long-term review cycle is expected in the coming years, and

     ·   A future update is possible later this decade as the committee evaluates whether changes are warranted.

For now, the standards remain stable—giving firms a window to refine methodologies, tighten policies, and align practices across teams.

Performance Methodology Under the SEC Marketing Rule

The Marketing Rule featured prominently again this year, and presenters emphasized a familiar theme: firms must apply performance methodologies consistently when private fund results appear in advertising materials.

Importantly, these expectations do not come from prescriptive formulas within the rule. They stem from:

1.     The “fair and balanced” requirement,

2.     The Adopting Release, and

3.     SEC exam findings that view inconsistent methodology as potentially misleading.

Common issues raised included: presenting investment-level gross IRR alongside fund-level net IRR without explanation, treating subscription line financing differently in gross vs. net IRR, and inconsistently switching methodology across decks, funds, or periods.

To help firms void these pitfalls, speakers highlighted several expectations:

     ·   Clearly identify whether IRR is calculated at the investment level or fund level.

     ·   Use the same level of calculation for both gross and net IRR unless a clear, disclosed rationale exists.

     ·   Apply subscription line impacts consistently across both gross and net.

     ·   Label fund-level gross IRR clearly, if used(including gross returns is optional).

     ·   Ensure net IRR reflects all fees, expenses, and carried interest.

     ·   Disclose any intentional methodological differences clearly and prominently.

     ·   Document methodology choices in policies and apply them consistently across funds.

This remains one of the most frequently cited issues in SEC exam findings for private fund advisers. In short: the SEC does not mandate a specific methodology, but it does expect consistent, well-supported approaches that avoid misleading impressions.

Evolving Expectations in Private Fund Client Reporting

Although no new regulatory requirements were announced, presenters made it clear that limited partners expect more transparency than ever before. The session included an overview of the updated ILPA reporting template along with additional information related to its implementation. Themes included:

     ·   Clearer disclosure of fees and expenses,

     ·   Standardized IRR and MOIC reporting,

     ·   More detail around subscription line usage,

     ·   Attribution and dispersion that are easy to interpret, and

     ·   Alignment with ILPA reporting practices.

These are not formal requirements, but it’s clear the industry is moving toward more standardized and transparent reporting.

Practical Insights from SEC Exams—Including How Firms Should Approach Deficiency Letters

A recurring theme across the SEC exam sessions was the need for stronger alignment between what firms say in their policies and what they do in practice. Trends included:

     ·   More detailed reviews of fee and expense calculations, especially for private funds,

     ·   Larger sample requests for Marketing Rule materials,

     ·   Increased emphasis on substantiation of all claims, and

     ·   Close comparison of written procedures to actual workflows.

A particularly helpful part of the discussion focused on how firms should approach responding to SEC deficiency letters—something many advisers encounter at some point.

Christopher Mulligan, Partner at Weil, Gotshal & Manges LLP, offered a framework that resonated with many attendees. He explained that while the deficiency letter is addressed to the firm by the exam staff, the exam staff is not the primary audience when drafting the response.

The correct priority order is:

1. The SEC Enforcement Division

Enforcement should be able to read your response and quickly understand that: you fully grasp the issue, you have corrected or are correcting it, and nothing in the finding merits escalation.

Your first objective is to eliminate any concern that the issue rises to an enforcement matter.

2. Prospective Clients

Many allocators now request historical deficiency letters and responses during due diligence. The way the response is written—its tone, clarity, and thoroughness—can meaningfully influence how a firm is perceived.

A well-written response shows strong controls and a culture that takes compliance seriously.

3. The SEC Exam Staff

Although examiners issued the letter, they are the third audience. Their primary interest is acknowledgment and a clear explanation of the remediation steps.

Mulligan emphasized that firms often default to writing the response as if exam staff were the only audience. Reframing the response to keep the first two audiences in mind—enforcement and prospective clients—helps ensure the tone, clarity, and level of detail are appropriate and reduces both regulatory and reputational risk.

Final Thoughts

With no changes to the GIPS standards introduced this year, the 2025 conference in Phoenix served as a reminder that the real challenges involve consistency, documentation, and communication. OCIO providers in particular should be preparing for the upcoming effective date, and private fund managers continue to face rising expectations around transparent, well-supported performance reporting.

Across all sessions, a common theme emerged: clear methodology and strong internal processes are becoming just as important as the performance results themselves.

This is exactly where Longs Peak focuses its work. Our team specializes in helping firms document and implement practical, well-controlled investment performance frameworks—from IRR methodologies and composite construction to Marketing Rule compliance, fee and expense controls, and preparing for GIPS standards verification. We take the technical complexity and turn it into clear, operational processes that withstand both client due diligence and regulatory scrutiny.

If you’d like to discuss how we can help strengthen your performance reporting or compliance program, we’d be happy to talk. Contact us.

From Compliance to Growth: How the GIPS® Standards Help Investment Firms Unlock New Opportunities

For many investment managers, the first barrier to growth isn’t performance—it’s proof.
When platforms, consultants, and institutional investors evaluate new strategies, they’re not just asking how well you perform; they’re asking how you measure and present those results.

That’s where the GIPS® standards come in.

More and more investment platforms and allocators now require firms to comply with the GIPS standards before they’ll even review a strategy. For firms seeking to expand their reach—whether through model delivery, SMAs, or institutional channels—GIPS compliance has become a passport to opportunity.

The Opportunity Behind Compliance

Becoming compliant with the GIPS standards is about more than checking a box. It’s about building credibility and transparency in a way that resonates with today’s due diligence standards.

When a firm claims compliance with the GIPS standards, it demonstrates that its performance is calculated and presented according to globally recognized ethical principles—ensuring full disclosure and fair representation. This helps level the playing field for managers of all sizes, giving them a chance to compete where it matters most: on results and consistency.

In short, GIPS compliance doesn’t just make your reporting more accurate—it makes your firm more credible and discoverable.

Turning Complexity Into Clarity

While the benefits are clear, the process can feel overwhelming. Between defining the firm, creating composites, documenting policies and procedures, and maintaining data accuracy—many teams struggle to find the time or expertise to get it right.

That’s where Longs Peak comes in.

We specialize in simplifying the process. Our team helps firms navigate every step—from initial readiness and composite construction to quarterly maintenance and ongoing training—so that compliance becomes a seamless part of operations rather than a burden on them.

As one of our clients put it, “Longs Peak helps us navigate GIPS compliance with ease. They spare us from the time and effort needed to interpret what the requirements mean and let us focus on implementation.”

Real Firms, Real Impact

We’ve seen firsthand how GIPS compliance can transform firms’ growth trajectories.

Take Genter Capital Management, for example. As David Klatt, CFA and his team prepared to expand into model delivery platforms, managing composites in accordance with the GIPS standards became increasingly complex. With Longs Peak’s customized composite maintenance system in place, Genter gained the confidence and operational efficiency they needed to access new platforms and relationships—many of which require firms to be GIPS compliant as a baseline.

Or consider Integris Wealth Management. After years of wanting to formalize their composite reporting, they finally made it happen with our support. As Jenna Reynolds from Integris shared:

“When I joined Integris over seven years ago, we knew we wanted to build out our composite reporting, but the complexity of the process felt overwhelming. Since partnering with Longs Peak in 2022, they’ve been instrumental in driving the project to completion. Our ongoing collaboration continues to be both productive and enjoyable.”

These are just two examples of what happens when compliance meets clarity—firms gain time back, confidence grows, and new business doors open.

Why It Matters—Compliance as a Strategic Advantage

At Longs Peak, we believe compliance with the GIPS standards isn’t a cost—it’s an investment.

By aligning your firm’s performance reporting with the GIPS standards, you gain:

  • Access to platforms and institutions that require GIPS compliant firms.
  • Credibility and trust in an increasingly competitive landscape.
  • Operational efficiency through consistent data and documented processes.
  • Scalability to support multiple strategies and distribution channels.

Simply put: compliance fuels confidence—and confidence drives growth.

Simplifying the Complex

At Longs Peak, we’ve helped over 250 firms and asset owners transform how they calculate, present, and communicate their investment performance. Our goal is simple: make compliance with the GIPS standards practical, transparent, and aligned with your firm’s growth goals.

Because when compliance works efficiently, it doesn’t slow your business down—it helps it reach further.

Ready to turn compliance into a growth advantage?

Let’s talk about how we can help your firm simplify the complex.

📧 hello@longspeakadvisory.com
🌐 www.longspeakadvisory.com

Performance reporting has two common pitfalls: it’s backward-looking, and it often stops at raw returns. A quarterly report might show whether a portfolio beat its benchmark, but it doesn’t always show why or whether the results are sustainable. By layering in risk-adjusted performance measures—and using them in a structured feedback loop—firms can move beyond reporting history to actively improving the future.

Why a Feedback Loop Matters

Clients, boards, and oversight committees want more than historical returns. They want to know whether:

·        performance was delivered consistently,

·        risk was managed responsibly, and

·        the process driving results is repeatable.

A feedback loop helps firms:

·        define expectations up front instead of rationalizing results after the fact,

·        monitor performance relative to objective appraisal measures,

·        diagnose whether results are consistent with the manager’s stated mandate, and

·        adjust course in real time so tomorrow’s outcomes improve.

With the right discipline, performance reporting shifts from a record of the past toa tool for shaping the future.

Step 1: Define the Measures in Advance

A useful feedback loop begins with clear definitions of success. Just as businesses set key performance indicators (KPIs) before evaluating outcomes, portfolio managers should define their performance and risk statistics in advance, along with expectations for how those measures should look if the strategy is working as intended.

One way to make this tangible is by creating a Performance Scorecard. The scorecard sets out pre-determined goals with specific targets for the chosen measures. At the end of the performance period, the manager completes the scorecard by comparing actual outcomes against those targets. This creates a clear, documented record of where the strategy succeeded and where it fell short.

Some of the most effective appraisal measures to include on a scorecard are:

·        Jensen’s Alpha: Did the manager generate returns beyond what would be expected for the level of market risk (beta) taken?

·        Sharpe Ratio: Were returns earned efficiently relative to volatility?

·        Max Drawdown: If the strategy claims downside protection, did the worst loss align with that promise?

·        Up- and Down-Market Capture Ratios: Did the strategy deliver the participation levels in up and down markets that were expected?

By setting these expectations up front in a scorecard, firms create a benchmark for accountability. After the performance period, results can be compared to those preset goals, and any shortfalls can be dissected to understand why they occurred.

Step 2: Create Accountability Through Reflection

This structured comparison between expected vs. actual results is the heart of the feedback loop.

If the Sharpe Ratio is lower than expected, was excess risk taken unintentionally? If the Downside Capture Ratio is higher than promised, did the strategy really offer the protection it claimed?

The key is not just to measure, but to reflect. Managers should ask:

·        Were deviations intentional or unintentional?

·        Were they the result of security selection, risk underestimation, or process drift?

·        Do changes need to be made to avoid repeating the same shortfall next period?

The scorecard provides a simple framework for this reflection, turning appraisal statistics into active learning tools rather than static reporting figures.

Step 3: Monitor, Diagnose, Adjust

With preset measures in place, the loop becomes an ongoing process:

1.     Review results against the expectations that were defined in advance.

2.     Flag deviations using alpha, Sharpe, drawdown, and capture ratios.

3.     Discuss root causes—intentional, structural, or concerning.

4.     Refine the investment process to avoid repeating the same shortcomings.

This approach ensures that managers don’t just record results—they use them to refine their craft. The scorecard becomes the record of this process, creating continuity over multiple periods.

Step 4: Apply the Feedback Loop Broadly

When applied consistently, appraisal measures—and the scorecards built around them—support more than internal evaluation. They can be used for:

·        Manager oversight: Boards and trustees see whether results matched stated goals.

·        Incentive design: Bonus structures tied to pre-defined risk-adjusted outcomes.

·        Governance and compliance: Demonstrating accountability with clear, documented processes.

How Longs Peak Can Help

At Longs Peak, we help firms move beyond static reporting by building feedback loops rooted in performance appraisal. We:

·        Define meaningful performance and risk measures tailored to each strategy.

·        Help managers set pre-determined expectations for those measures and build them into a scorecard.

·        Calculate and interpret statistics such as alpha, Sharpe, drawdowns, and capture ratios.

·        Facilitate reflection sessions so results are compared to goals and lessons are turned into process improvements.

·        Provide governance support to ensure documentation and accountability.

The result is a sustainable process that keeps strategies aligned, disciplined, and credible.

Closing Thought

Markets will always fluctuate. But firms that treat performance as a feedback loop—nota static report—build resilience, discipline, and trust.

A well-structured scorecard ensures that performance data isn’t just about yesterday’s story. When used as feedback, it becomes a roadmap for tomorrow.

Need help creating a Performance Scorecard? Reach out if you want us to help you create more accountability today!