I recently conducted a “mini verification” for a client wanted us to do a high level check on a manager who both claimed compliance with the Global Investment Performance Standards (GIPS(R)) and had been verified.
As I always do, I asked to see all their composite presentations. While they could provide most, they couldn’t for the “non-marketed” ones. And while they “knew” they are supposed to have them, their verifier never asks for them so they hadn’t bothered to prepare them.
Well, I’m not surprised as there are some verifiers who believe that verification only deals with “marketed composites,” and that the firm has no obligation to do anything with the “non-marketed” ones. To me, this is shameful. Verification is a “firm wide” exercise, not limited to only the “marketed composites.”
I’ve addressed this point with this particular verifier on multiple occasions but clearly they have their own rules which they live by (GIPS rules be damned). To me, they’re doing a disservice to their clients. First, they are claiming to conduct a “verification,” but are actually doing only part of the job. This expeditious approach may have appeal, but it puts the client at risk. What if I were the SEC asking for these presentations? Might the firm’s claim of compliance be questionable, posing the possibility of a sanction?
To this verifier and others who argue in favor of only worrying about the marketed composites I ask a simple question: what page in the standards do the words “marketed composites” appear? I have yet to find it.
p.s., As an aside, to make up for not verifying all the composites the verifier was able to talk this firm into examining ALL of the marketed composites: you know what I have to say about examinations.