Performance Perspectives Blog

Some thoughts on GIPS Policies & Procedures

by | Apr 19, 2018

I never had any ambition to write. In fact, I had little interest in studying English, grammar, or any of its related topics. I was always a “math guy,” and had somehow concluded (falsely, as it turns out) that you can either be good at math or English, but not both.

However, upon graduating from Temple University with my Bachelor’s in mathematics four-plus decades ago, I quickly learned that I would be required to write. And, over the years the degree of writing in which I became engaged with only increased. Fortunately, I have become quite fond of writing, and have made it a passion to learn as much as possible about it and to do as good a job as I can.

Those who work with me know of my fondness for critiquing just about everything that leaves our firm. This includes advertising materials, press releases, marketing pieces, etc.

My verification clients, too, often find me commenting on their writing. This will be when it comes to their GIPS Policies & Procedures, and occasionally their presentations. GIPS® (Global Investment Performance Standards) requires compliant firms to have written policies and procedures. The individuals responsible for a firm’s compliance often develop and/or maintain their firm’s GIPS Policies & Procedures.

The Spaulding Group recently held P&P contest which I posted about in February.

Today’s post does not address the content of a firm’s GIPS Policies & Procedures but more their style. Just a few thoughts picked up over the past 46 years of more serious writing.

Note that what you’ll find here can often be considered nit-picky, for which I make no excuse and offer no apology. Much of this will, I suspect, also appear in various style guides.

Your firm’s GIPS Policies & Procedures Should Have a ToC

Unless your GIPS Policies & Procedures are quite short, you probably should have a ToC, or Table of Contents.

And ideally, this ToC should have page numbers, not just the list of what’s included in the GIPS Policies & Procedures.

And, from a pagination standpoint, I would refrain from numbering the ToC’s page. I also refrain from numbering the cover page. I.e., page #1 begins with the first page of actual P&P text.

One challenge with ToCs is keeping the numbers straight. If you’ve created it manually, such that you had to enter each page number for each of the sections listed, then whenever you add or remove text, you’ll need to check to ensure that there aren’t any changes. It’s not very good if your ToC tells me that the section on error correction is on page 14, when it’s actually on page 15 (I guess being close is helpful, but …).

While I cannot speak for MS/Word, WordPerfect provides an automatic ToC generator. Upon request, it will renumber when necessary. MS/Word probably has something like it, but I’ve never worked with it, so can’t really say.

Your page numbers: odd on the right, even on the left

Open any book and what will you find? The pages on the right will have odd numbers, while the ones on the left are even numbers. YEARS ago, our [then] printer goofed and printed an issue of The Journal of Performance Measurement® with the opposite. Because we failed to catch the error during our proofing, we ended up paying for a complete reprint. But, there was no way I was going to allow the journal to go out with the pages not numbered properly.

While your P&P will probably not be shared publicly, I’d still encourage you to try to have your page numbers adhere to this convention. Of course, if you don’t print double-sided, then this probably won’t matter.

Numbering: write as a number or spell out?

There are apparently a variety of related rules on this, with quite a bit of consistency (see, for example, what Grammar Girl says on this). The rule I know is what Grammar Girl calls for: you spell out numbers from one to nine (ten’s optional).

If, for example, you state that you will not report a measure of dispersion if there are 5 or fewer accounts present for the full year, I suggest you change the “5” to “five.”

Avoiding widows & orphans

As per Wikipedia:

  • Widow: A paragraph-ending line that falls at the beginning of the following page or column, thus separated from the rest of the text.
  • Orphan: A paragraph-opening line that appears by itself at the bottom of a page or column, thus separated from the rest of the text.

If your paragraph has more than two lines, you should avoid having a single line at a page’s top or bottom. If the paragraph has two or three lines, try to keep them together. If four, then either have them all on the same page, or make sure two are at the bottom and two at the top of consecutive pages.

Don’t leave a heading all by itself at the bottom of a page

If you find that you’ve started a new section at the bottom of a page, and that the first line appears on the next page, it’s best to adjust your document so that the heading will also be at the top of the next page.

Watch your grammar and spelling!

Yes, when reviewing a client’s P&P I do comment on grammar and spelling.

My first year in pursuit of my doctorate we did weekly writing assignments. One student asked “does spelling count?” I was a bit surprised that this would have been brought up. The professor [not surprisingly] said “yes, it would.” I was then even more surprised when I read what some students wrote. Not only was spelling often incorrect (despite the availability of “spell check” within their word processor), but their grammar was often replete with errors. These were students who not only had an undergraduate degree, but also at least one graduate degree! I guess many make it through not just high school, but college, too, without developing good writing skills.

For the most part, our clients are very good writers, so it’s rare that I have much to say. And my comments are usually quite minor (and, I will flag them as “minor” in my report).

The mistakes they make are ones that many folks do. For example, failing to properly use apostrophes for possession (and distinguishing between single vs. plural possession: whether the apostrophe falls before or after the “s”), capitalizing non-proper nouns, or getting i.e. and e.g. confused.

What else do I comment on?

If I think that a firm’s GIPS Policies & Procedures can be improved upon, I’ll let the client know. This can be such things as changing from passive to active voice, adjusting the phrasing of a statement, eliminating redundancies, or shifting the location of paragraphs.

Why do I comment on this in my reports?

As noted above, when I review a firm’s GIPS Policies & Procedures I’ll comment on their writing. I do this because I believe that if I’m reading them and find something that can be improved or corrected, why not tell them? If they elect not to change it, that’s their choice. Most of our clients seem to like learning of ways to make improvements. If someone objected, I’d stop, but so far, I haven’t heard any complaints.

There’s a saying that goes something like “there’s no such thing as writing, just rewriting.” That is, once you write something, be prepared to edit it. Don’t stop with a single draft.

When I review a client’s materials, I may miss something the first few times that can result in an improved document. This happens within our firm, too. I’ll be sent a text to review, and may offer a series of comments/corrections. When I’m sent the revision, I’ll see that what I asked to be changed has been, but will now discover a few more items. My team is used to this.

A brief [funny?] story about our newsletter

Several years ago, we considered using a third-party to prepare our monthly newsletters. This service was one that would provide quite a bit of non-technical materials, but also include some performance/risk measurement related content that we would provide.

They sent us a sample, and I was a bit surprised by the errors I found: both grammar and spelling.

This was apparently a standard example that this firm would provide prospects. So, when we let them know of the errors, we thought they would respond with something like “we’re a bit embarrassed by your discovery. These errors should definitely have been caught, and we’re surprised no one else has brought this to our attention. Thank you for sharing this. We will correct this right away, and will assure you that such mistakes will not happen with your materials.”

Instead, we were told that our expectations were apparently too high for them. They suggested we seek another vendor. We elected to avoid outsourcing this task, and continue to do these materials ourselves.

Writing beyond P&Ps

I think it is fair to say that everyone writes a great deal more today than they ever expected. Not only are we occasionally asked to prepare documents such as GIPS Policies & Procedures, we:

  • regularly write emails
  • post on social media
  • message people.

Should “style” count here, too? Well, that’s highly debatable. Many consider emails to be less formal, and therefore not as spelling/grammar sensitive as formal documents. I happen to fall into the other camp: the one that thinks that whatever we write should be correct.

But don’t worry: if you send me an email with any errors, I will not comment (unless, perhaps, you work for The Spaulding Group!).

Please let us know your thoughts!

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