We held a webinar on Monday devoted to the GIPS(R) (Global Investment Performance Standards) Error Correction Guidance Statement. As I pointed out in the session, this GS is one of the most confusing that has been offered, though the newest version is definitely much improved of the prior edition.
A verification client sent me a question, which is one that perhaps is worth commenting on here:The Guidance Statement on Error Correction indicates that disclosure of the change must be included In the respective compliant presentation for a minimum of 12 months following the correction of the compliant presentation. In what situations would the firm be required to continue to disclose the change to the erroneous presentation for a minimum of the following 12 months if the firm has already provided all persons that received the erroneous presentation with a corrected presentation that contains disclosure about of the change?
There are two possible scenarios when it comes to the disclosure of “material errors”:
- The firm has kept track of the recipients of their presentations
- The firm has not kept track of the recipients of their presentations.
If the client has kept track, then this 12-month rule doesn’t apply, since they will have two versions of their presentations (one with the disclosure, which they will give to those prospects who are (a) still active prospects or (b) have become clients in the interim; the second with no disclosure, which will be given to new prospects who didn’t see the version with the error).
If the client failed to keep track, then they have a single version of the presentation, which will contain the disclosure, and which they will give to everyone (both new prospects as well as any prospects that saw the version which they know of).
Hope this makes sense!