Firms that are GIPS compliant are required to provide all prospective clients with a GIPS compliant presentation. Typically, each composite has its own separate one-page sheet that includes all the statistics and disclosures required for that composite. This one-page sheet can be attached as an appendix to your firm’s pitchbooks and other marketing materials to properly represent your firm to the public as a GIPS compliant firm.
Not all compliant presentations are the same. Your firm’s required statistics and disclosures will depend on your firm’s strategies and policies. In this article, we discuss the required statistics and disclosures applicable to most GIPS compliant firms. In addition, we provide information on common issues firms face when creating compliant presentations and what you might be able to do to avoid them.
Required GIPS Statistics
Although additional statistics may be required, the following are the most common statistics that GIPS compliant firms are required to present in their compliant presentations:
- Annual composite time-weighted returns (gross and/or net) – GIPS recommends the use of gross-of-fee returns; however, at least in the United States, it is most common to include both gross and net-of-fee returns. Net returns can be based on actual management fees or a model fee. As discussed in a previous post titled “Are fee-related administrative issues causing errors in your investment performance?” using a model fee instead of actual fees may be necessary when you have clients that pay fees from an outside source (e.g., by check or from another account your firm manages for them).
- Annual benchmark returns – GIPS requires the use of a benchmark unless you are able to disclose a reason why no meaningful benchmark is available. Even if your strategy is benchmark agnostic, most firms choose to include the most relevant benchmark available and then disclose any material differences between the benchmark and the strategy.
- Number of portfolios in the composite as of each year-end – This is simply the number of portfolios that are included in the composite as of 31 December each year.
- Total assets in the composite as of each year-end – This is simply the sum of the composite assets as of 31 December each year.
- Total assets of the GIPS firm as of each year-end – This is the sum of all discretionary and non-discretionary portfolio assets that are included in the firm definition as of 31 December each year.
- A measure of internal dispersion for each annual period – Internal dispersion is a measure used to give the user of the performance report an indication as to how tightly the strategy is managed. In other words, if you are reporting that the composite return was 10% for the most recent annual period, a low internal dispersion figure will tell the user that most portfolios in the composite returned approximately 10%. High dispersion would indicate that the portfolios in the composite had a more diverse set of returns (e.g., perhaps some returned 5% while others returned 15%). Typically, firms use standard deviation to present this, which can either be calculated on an equal-weighted or asset-weighted basis.
- Three-year annualized ex-post standard deviation of both the composite and the benchmark based on monthly returns – This is a measure of risk. The standard deviation of the composite’s monthly returns and the benchmark’s monthly returns provides the user of the performance report an idea of the level of risk taken compared to the benchmark. Ideally, you want higher annual returns and lower annualized standard deviation compared to the composite’s benchmark. That would indicate that you were able to outperform while taking less risk. For composites where a different measure of risk would be more meaningful than standard deviation, firms may present an additional risk measure with an explanation as to why that measure is more relevant, but the annualized standard deviation must still be included.
Other statistics may also be required if, for example, your firm manages non-fee-paying or bundled-fee accounts. Firms with these types of accounts must show the percentage of the composite they represent as of each year-end. Firms with private equity or real estate composites also require different statistics which can be found in the Real Estate and Private Equity provisions of the GIPS Standards.
When reviewing compliant presentations before distribution, many firms focus purely on the statistics presented to ensure material errors do not exist. This is often done without realizing that missing or incorrect disclosures can also be considered a material error. Thus, you’ll want to make sure your review process incorporates an evaluation of both.
The disclosures that must be included in a GIPS compliant presentation will differ by firm and by composite. Rather than listing all of them here, we have compiled a checklist of required GIPS disclosures which can be used as part of your firm’s marketing material review process. This checklist can be used to help you incorporate the proper disclosures for each compliant presentation prior to approving them for external use.
When reviewing the disclosures included in your firm’s GIPS compliant presentations, it is important to ensure:
- No required disclosures are missing.
- The disclosures are consistent with the policies documented in your
GIPS Policies and Procedures document (“GIPS P&P”), including any
recent changes to policies. For example, if a minimum asset level is
changed for a composite, it is important to ensure that this change is
- documented in your firm’s GIPS P&P,
- implemented in the actual composite construction, and
- disclosed in the GIPS compliant presentation.
- Any disclosures (such as the claim of compliance) that are required to be written word-for-word as stated in the standards, are not modified in any way.
Firms that do not have composite maintenance software or an external GIPS consultant to create their GIPS compliant presentations often create them manually. When creating and updating compliant presentations yourself, it is important to avoid theses common mistakes:
- Don’t double count assets. For example, if the same portfolio is included in more than one composite you will not be able to sum your composite assets to get to your total GIPS firm assets. Additionally, if you manage a fund and then some of the separate accounts you manage invest in that fund as part of their portfolio, you need to ensure you do not count those assets both as part of the fund and again as part of the separate accounts. It is also important to ensure that only actual accounts are included. Models and anything that is considered “advisory-only” should be excluded from your calculation.
- Ensure that the number of portfolios reported is the total number of portfolios included in the composite as of 31 December of that year. Since internal dispersion is calculated based on only the portfolios that were in the composite for the full year, some firms make the mistake of reporting their number of portfolios as just the number of portfolios that were included for the full year. This is not correct as this statistic is intended to be the total number of portfolios in the composite as of each year-end.
- When partial-year performance is presented, it is important to:
- Clearly label the period for which performance is presented.
- Match the benchmark period to the period presented for the composite.
- Keep your presentations up-to-date. This means:
- Updating presentations with corrected statistics if corrections are made to the composite’s data. For example, firms may make updates to transactions for reconciliation purposes, such as backdating dividends. If this results in a change to composite-level statistics, then the compliant presentations must be updated accordingly. It is important to consistently follow your firm’s GIPS error correction policy. Typically, immaterial changes to the statistics are updated for future use even if the changes are not large enough to trigger redistribution of the presentation.
- Updating presentations with the most recent year’s statistics as soon as they become available. It is not necessary to wait for the verification to be complete before adding and presenting updated statistics. For example, if your annual GIPS verification for calendar year 2017 will not be complete until mid-2018, you do not need to wait until the verification is complete to present the 2017 statistics in your compliant presentation. You just cannot update the date your firm is verified through until the verification report is issued (i.e., you can present unverified statistics for the 2017 period, but the date range of your verification will still be disclosed as ending 31 December 2016). This lets the user of your compliant presentation have the latest statistics while letting them know that the verification for the latest period is pending.
- Ensure there are no typos if you are manually entering the statistics into a table. Typos can easily cause material errors that would trigger the need for redistribution of the presentation with disclosure of the error. Establishing a simple review process can help your firm avoid this headache.
- Make sure the information for each composite is entered into the correct compliant presentation (i.e., ensure you do not enter the statistics for Composite A into the presentation for Composite B). Seems obvious, but you’d be surprise how often this mistake is made. Again, a reliable review process can help your firm avoid these mistakes.
Want to Learn More?
If you have any questions about creating compliant presentations or any GIPS statistics or disclosures, we would love to help. Longs Peak’s professionals have extensive experience helping firms become GIPS compliant as well as helping them maintain compliance with the GIPS Standards on an ongoing basis. Contact us to learn how we can help.
Sean P. Gilligan, CFA, CPA, CIPM is the Managing Partner of Longs Peak Advisory Services, LLC. He has 20 years of experience in the investment industry and he specializes in GIPS compliance and investment performance consulting. Visit our website or contact us for more information on our firm and services.