I spent a few hours reviewing the 100+ comment letters that were submitted in response to the proposed changes to the GIPS standards, and want to give you an indication of what folks wrote, at least on a few key issues. I don’t envy the CFA Institute staff who will no doubt have to go through these letters, line by line, to dissect what’s been offered.
Paragraph 3.A.9 was presented as a change from a “recommendation” to a “requirement,” but I’ve mentioned more than once that this isn’t exactly correct. The current wording speaks of firms not “marketing” to prospects below their minimum, while the proposed requirement calls for firms not providing presentations to these prospects. While I’m very sure there was no intent to mislead anyone, the wording is still a bit confusing. Well over half the individuals who offered their thoughts on the standards took the time to comment on this provision, with an overwhelming majority opposing this proposed change.
Paragraph 0.A.7 alters the wording for the compliance statement, in that a reference is made regarding the firm’s status vis-a-vis verification. Three statements were proposed: currently verified, not verified, and verified but not current (i.e., stale). Very few individuals opposed the introduction of this new statement, although a very large number preferred only having two status statements: verified or not. Interestingly, an accompanying provision defines “current” as being verified within the past two years. The comments here were quite mixed, ranging from a recommendation that the time period be narrowed to a single year, to dropping the qualification completely.
Roughly 25% of the respondents commented on the new proposed requirement to disclose if there were any material errors corrected in the presentation for a year (paragraph 4.A.28), and by far the majority opposed such a requirement.
I’ll stop here for now, and will discuss other comments later.