Key Takeaways from the 2023 GIPS® Standards Conference

Sean P. Gilligan, CFA, CPA, CIPM
Managing Partner
October 23, 2023
15 min
Key Takeaways from the 2023 GIPS® Standards Conference

CFA Institute hosted the 27th annual GIPS Standards Conference on October 17th - 18th 2023 in Chicago, Illinois. As expected, it was filled with a lot of familiar faces, but also had quite a few first timers, which was nice to see.

Being almost a year into the SEC Marketing Rule and with implementation of the Private Fund Adviser Quarterly Statement Rule on the horizon, the hottest topics of this year’s conference were the sessions relating to regulatory compliance. These sessions included discussions with representatives from the U.S. Securities and Exchange Commission (“SEC”) answering practical questions related to adherence to these rules as well as sessions with senior performance professionals discussing the detailed performance methodology required to comply.

Other topics included a review of the proposed guidance statement for applying the GIPS standards to OCIOs, helpful advice for updating consultant databases, a proposed method to risk-adjust performance attribution, and some lessons on soft skills for leaders managing relationships.

SEC Marketing Rule

Michael McGrath, CFA, Partner with Dechert LLP and Robert Shapiro, Assistant Director, Division of Investment Management with the SEC together with Karyn Vincent, CFA, CIPM and Krista Harvey, CFA, CIPM of CFA Institute did an excellent job emphasizing the key lessons learned as we near the 1-year mark of the adoption of the Marketing Rule. Below are some key takeaways worth noting:

Defining “Performance”

Since the Marketing Rule requires investment managers to present performance net-of-fees, it is important for firms to define what they consider “performance.” The SEC takes a straightforward approach, generally considering any statistic that demonstrates how much an investor earned from an investment to be performance. But, even with this simple and easy to understand approach, there can be some grey areas.

Based on the discussions in this session, it seems to now be widely accepted that in addition to basic returns being considered performance that contribution is also considered performance, while attribution and most performance appraisal measures are not considered performance. Performance appraisal measures should be individually considered to confirm if they are demonstrating the amount earned (which would be performance) or if it is used as a measure of the manager’s skill(which would not be considered performance).

Some portfolio characteristics could also be a grey area that firms should be careful to consider before presenting solely as gross-of-fees. For example, yield was discussed at length. It was said that total portfolio yield for something like an enhanced cash portfolio likely would be performance because the yield in that case is essentially the return the investor earned. On the other hand, dividend yield for a growth strategy where this does not directly indicate the amount the investor earned *might* be performance. This really would come down to how it is presented and how material the yield is to the strategy. If material to the strategy’s return, this may be considered performance and, in this case, would need to be reduced by a model fee.

After determining that a statistic is not performance and will be presented based on gross-of-fee input data, it is important to clearly label these figures as gross. A disclosure under the table or chart that simply states something like, “Risk statistics are presented gross-of-fees,” should suffice.

There was also a lot of discussion relating to applying fees to extracted performance such as sector and holdings-level performance. It was made very clear that each segment must be reduced and presented net-of-fees so fees cannot just hit the cash segment or something like that. To achieve this, most firms are using a model fee. For example, if the highest fee for the strategy is 1% per year and quarterly sector returns are presented, each sector’s quarterly return is reduced by 0.25%.

Hypothetical Performance

Hypothetical performance has been a focus of the initial SEC enforcement actions taken against firms under the Marketing Rule. The main issue has been firms broadly distributing hypothetical performance without any policies and procedures in place to ensure the distribution of this type of performance is limited only to those that can be reasonably expected to understand it.

The key is that firms must document policies that clearly define the intended audience for a particular presentation of hypothetical performance and then ensure that the presentation only goes to this audience. In addition, documentation should include the tools necessary to understand the information provided. For example, the type of hypothetical performance should be clearly described as well as any assumptions made to create this performance.

Hypothetical performance is very broadly defined. It could be anything from a back-tested model to a paper portfolio or even just an aggregation of extracted returns (e.g., a composite of carveouts). It should be clear what the performance represents and consideration should be given to the complexity of the information, especially when determining it’s appropriate audience.

Private Fund Adviser Quarterly Statement Rule

Anne Anquillare, CFA, Head of US Fund Services with CSC Global Financial Markets and Pamela Grossetti, Partner with K&L Gates together with Krista Harvey, CFA, CIPM of CFA Institute walked us through the key elements to prepare for with the new Private Fund Adviser Quarterly Statement Rule. Below are some key takeaways worth noting:

The Compliance Date for the Quarterly Statement Rule is March 14, 2025. This may sound like a long time away, but it is important to keep in mind that the requirement to include cross-references to the underlying governing documents in the Quarterly Statement may require amendments to such documents before the first Quarterly Statement is issued, and this could be time consuming.

Under this new rule, private fund managers must distribute a quarterly statement to the investors in the fund within 45 days after each quarter ends and 90 days after year-end. This is required for any private fund that has at least two full quarters of operating results.

There are many items that must be included in the quarterly statements relating to general fund details like fees and expenses as well as disclosures that are cross-referenced to the private fund’s offering documents; however, being the GIPS conference, this presentation was primarily focused on the performance requirements.

The performance requirements for liquid funds are very different for illiquid funds. An illiquid fund is one that is not required to redeem interests when requested by an investor and has limited opportunities for an investor to withdraw funds prior to the fund’s termination. If a fund manager determines that their fund is liquid, the performance requirement for the quarterly statement is limited to showing the following three items, each in equal prominence:

  1. Annual net-of-fee returns for each of the past 10 fiscal years (or back to inception if shorter)
  2. Annualized net-of-fee returns for the past 1, 5, and 10 years through the end of the latest fiscal year (or since inception if shorter)
  3. Year-to-date net-of-fee return for the current fiscal year

Illiquid funds have a much more significant requirement with 12 figures they are required to present:

Portfolio-Level

Investment-Level

Unlike the GIPS standards, under this rule, there is no exemption for funds that only use a subscription line of credit for a short period of time. Funds that utilize a subscription line of credit for any period are required to show the metrics listed above both with and without the subscription line.

Another notable difference from the GIPS standards is that this rule requires interest expense charged from the subscription line of credit to be added back when calculating the “without subscription line of credit” version of the required metrics. The GIPS standards do not require this adjustment.

It was also discussed that if these quarterly statements were provided to prospective investors instead of only current investors then they would also need to be reviewed to confirm that they meet the Marketing Rule on top pf the Quarterly Statement Rule.

Current State of SEC Exams

Mark Dowdell, Assistant Regional Director with the SEC together with Ken Robinson, CFA, CIPM from CFA Institute discussed current trends in SEC examinations. Below are some key takeaways worth noting:

There was a strong emphasis on the need for clear policies and procedures that have been customized for the firm. Specifically, it was emphasized that policies and procedures relating to hypothetical performance are not the only thing firms should make sure they add for the Marketing Rule. For example, if firms are presenting predecessor performance or extracted performance there should be documented policies for this as well.

It was mentioned that in addition to standard examinations, the SEC is also conducting some risk-based exams that may be limited in scope, but go very deep on a narrow area. This may even include the recalculation of performance in their own systems to get comfortable with the accuracy of presented figures.

Outside of the recent enforcement actions relating to hypothetical performance, the SEC continues to see firms make exaggerated or untrue statements relating to the number of staff they employ, the qualifications of staff, awards received, the use of AI in the investment process, and their adherence to ESG standards in the investment process. While it is okay to state opinions in marketing materials, statements of fact absolutely must be substantiated.

Developing a Database Strategy

Jill Banaszak, Global Head of Omni Success at eVestment lead a great session on getting the most out of 3rd party and consultant databases.

The most important takeaway was the importance of using databases to tell the story of your firm in a complete and accurate way. Often firms leave a number of fields blank or neglect to revisit (or update) the narrative sections to remain accurate and in sync with their other messaging online or in marketing materials. Asset owners and their representatives use the databases to make short lists of firms meeting their criteria and many firms end up excluded as a result of blank fields or inconsistencies in messaging. At a minimum, firms should target completing at least 80% of the requested information.

It is also important to ensure information is completed timely and accurately. Firms should have monthly figures updated by the 12th business day of the month at the latest to avoid missing out on searches. To avoid errors or incomplete information, firms should consider who is tasked with updating the information and also ensure this person or team is qualified and has access to all relevant information so it can be fully completed. Implementing a quality control process to double check the information is also important to avoid typos or other mistakes in the information presented.

Applying the GIPS Standards to OCIOs

There is currently an exposure draft of the Guidance Statement for OCIO Strategies out for public comment with comments due by 20 November 2023. This session was led by a group of panelists who were part of the OCIO working group that created this new guidance statement. The purpose of this guidance statement is to improve comparability between OCIO strategies. The primary change in this proposed guidance that deviates from the current requirements of the GIPS standards for firms is the required composite structure that all OCIO managers would need to follow.

The required composite structure would separate liability-focused composites from total return objective composites and would then further break the composites down by their allocation between risk mitigating assets and growth assets ranging from conservative to aggressive allocations. There are specific weightings defined for each that are intended to line up with commonly used OCIO benchmarks.

These new composites are only required to build out five years of history, but like other composites firms manage, must then build up to showing a ten year track record before any performance periods can be removed.

This guidance statement also proposes requiring both gross-of-fee returns and net-of-fee returns instead of only one because of the complexity of OCIO fees.

This guidance statement has not yet been officially adopted, but once approved, it is expected to allow for a 12-month implementation period for firms to update their policies and procedures, construct composites that align with the prescribed composite structure, and create GIPS reports for these new composites.

Conclusion

This year’s speakers did a great job providing clarification on the SEC Marketing Rule and other relevant topics that impact GIPS compliance and investment performance.

We were happy to see many old friends in person this year in Chicago and look forward to seeing everyone again next year in San Diego. It was announced that next year’s conference will be held on the 17th – 18th of September in San Diego, California!

If you have any questions about the 2023 GIPS Standards Conference topics or GIPS compliance and performance measurement in general, please contact us.

*A previous version of this article included a mistake for investment-level figures for illiquid funds. This has been corrected.

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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.

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🌐 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!

When you're responsible for overseeing the performance of an endowment or public pension fund, one of the most critical tools at your disposal is the benchmark. But not just any benchmark—a meaningful one, designed with intention and aligned with your Investment Policy Statement(IPS). Benchmarks aren’t just numbers to report alongside returns; they represent the performance your total fund should have delivered if your strategic targets were passively implemented.

And yet, many asset owners still find themselves working with benchmarks that don’t quite match their objectives—either too generic, too simplified, or misaligned with how the total fund is structured. Let’s walkthrough how to build more effective benchmarks that reflect your IPS and support better performance oversight.

Start with the Policy: Your IPS Should Guide Benchmark Construction

Your IPS is more than a governance document—it is the road map that sets strategic asset allocation targets for the fund. Whether you're allocating 50% to public equity or 15% to private equity, each target signals an intentional risk/return decision. Your benchmark should be built to evaluate how well each segment of the total fund performed.

The key is to assign a benchmark to each asset class and sub-asset class listed in your IPS. This allows for layered performance analysis—at the individual sub-asset class level (such as large cap public equity), at the broader asset class level (like total public equity), and ultimately rolled up at the Total Fund level. When benchmarks reflect the same weights and structure as the strategic targets in your IPS, you can assess how tactical shifts in weights and active management within each segment are adding or detracting value.

Use Trusted Public Indexes for Liquid Assets

For traditional, liquid assets—like public equities and fixed income—benchmarking is straightforward. Widely recognized indexes like the S&P 500, MSCI ACWI, or Bloomberg U.S. Aggregate Bond Index are generally appropriate and provide a reasonable passive alternative against which to measure active strategies managed using a similar pool of investments as the index.

These benchmarks are also calculated using time-weighted returns (TWR), which strip out the impact of cash flows—ideal for evaluating manager skill. When each component of your total fund has a TWR-based benchmark, they can all be rolled up into a total fund benchmark with consistency and clarity.

Think Beyond the Index for Private Markets

Where benchmarking gets tricky is in illiquid or asset classes like private equity, real estate, or private credit. These don’t have public market indexes since they are private market investments, so you need a proxy that still supports a fair evaluation.

Some organizations use a peer group as the benchmark, but another approach is to use an annualized public market index plus a premium. For example, you might use the 7-year annualized return of the Russell 2000(lagged by 3 months) plus a 3% premium to account for illiquidity and risk.

Using the 7-year average rather than the current period return removes the public market volatility for the period that may not be as relevant for the private market comparison. The 3-month lag is used if your private asset valuations are updated when received rather than posted back to the valuation date. The purpose of the 3% premium (or whatever you decide is appropriate) is to account for the excess return you expect to receive from private investments above public markets to make the liquidity risk worthwhile.

By building in this hurdle, you create a reasonable, transparent benchmark that enables your board to ask: Is our private markets portfolio delivering enough excess return to justify the added risk and reduced liquidity?

Roll It All Up: Aggregated Benchmarks for Total Fund Oversight

Once you have individual benchmarks for each segment of the total fund, the next step is to aggregate them—using the strategic asset allocation weights from your IPS—to form a custom blended total fund benchmark.

This approach provides several advantages:

  • You can evaluate performance at both the micro (asset class) and macro (total fund) level.
  • You gain insight into where active management is adding value—and where it isn’t.
  • You ensure alignment between your strategic policy decisions and how performance is being measured.

For example, if your IPS targets 50% to public equities split among large-, mid-, and small-cap stocks, you can create a blended equity benchmark that reflects those sub-asset class allocations, and then roll it up into your total fund benchmark. Rebalancing of the blends should match there balancing frequency of the total fund.

What If There's No Market Benchmark?

In some cases, especially for highly customized or opportunistic strategies like hedge funds, there simply may not be a meaningful market index to use as a benchmark. In these cases, it is important to consider what hurdle would indicate success for this segment of the total fund. Examples of what some asset owners use include:

  • CPI + Premium – a simple inflation-based hurdle
  • Absolute return targets – such as a flat 7% annually
  • Total Fund return for the asset class – not helpful for evaluating the performance of this segment, but still useful for aggregation to create the total fund benchmark

While these aren’t perfect, they still serve an important function: they allow performance to be rolled into a total fund benchmark, even if the asset class itself is difficult to benchmark directly.

The Bottom Line: Better Benchmarks, Better Oversight

For public pension boards and endowment committees, benchmarks are essential for effective fiduciary oversight. A well-designed benchmark framework:

  • Reflects your strategic intent
  • Provides fair, consistent measurement of manager performance
  • Supports clear communication with stakeholders

At Longs Peak Advisory Services, we’ve worked with asset owners around the globe to develop custom benchmarking frameworks that align with their policies and support meaningful performance evaluation. If you’re unsure whether your current benchmarks are doing your IPS justice, we’re hereto help you refine them.

Want to dig deeper? Let’s talk about how to tailor a benchmark framework that’s right for your total fund—and your fiduciary responsibilities. Reach out to us today.