Performance Perspectives Blog

GIPS standards changes via the Handbook

by | Jun 28, 2013

We are discovering new changes to GIPS(R) (Global Investment Performance Standards) that have been introduced through the most unusual ways: not as part of the Standards, but simply as Q&As or notes. How are we to learn of these? I guess by reading the entire book (sorry, but I fall asleep when I try) and monitoring Q&As on a regular basis.

And so, what we will do is make you aware, most likely through The Spaulding Group’s Newsletter, and occasionally through this blog, of changes that we encounter or that are reported to us. We’ll begin with the July edition of the Newsletter, since the June will be published shortly. If you find any changes, please alert us, and we’ll make sure they get posted.

The latest change we found (specifically, Jed Schneider discovered it) was the introduction of “sunset rules.”  You may recall that I suggested that these be incorporated into GIPS 2015 (which won’t happen, of course). But, someone decided to slip them in. Who that may be is unknown; all we know is they’re there. For example:

While I am pleased to see them being introduced, why wasn’t the public given the opportunity to review and comment? That was the old way: changes to the Standards are put out for public comment. But apparently that’s no longer the case.

What is the basis for this? Is this just one person’s idea, the work of a committee, or what? This is CLEARLY a change; but instead of being IN the Standards, it’s in a note. Which, you have to go looking for.

And so, if you discover items like this, please just send me an email, and I’ll make sure they get published so folks can learn about them.

p.s., a colleague who is “in the know” pointed out that there was actually an earlier Q&A that addressed this subject:

How long does a composite name change disclosure have to be presented?

The disclosure must be included in the composite’s compliant presentation for as long as it is relevant to support the performance presentation. The disclosure must be included for a minimum of one year and potentially for more than one year if the firm determines the disclosure is still relevant and meaningful. The firm must consider the underlying principles of the Standards of full and fair disclosure when determining a course of action.

  • Categories: Disclosures
  • Date Added: January 2008
  • Source: The GIPS Standards 2005 edition

I was unaware of this item and would have reacted in a similar way: where in the Standards is it permitted for a firm to determine “relevance”? That’s a totally new concept to me: relevance! I know we speak of “materiality,” but “relevance”? And so, can we extend this to all items? That is, an item is required ONLY IF IT’S RELEVANT! The U.S. Supreme Court (as well as courts from many nations) use precedents to determine what action to take or allow. To me, THIS set a precedent; don’t you agree? It clearly gives firms the option to determine “relevance” when it comes to provisions.

Also, since this was published prior to the 2010 edition, why wasn’t this wording brought into the Standards themselves? It’s clearly a new rule; shouldn’t it be more visible?

I’ll have more to say on this.

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