A GIPS(R) (Global Investment Performance Standards) verification client sent me this question, just before our Labor Day weekend break (and I’ll paraphrase): if we change or remove supplemental information, must we disclose it?
Neither the Standards nor the Supplemental Information Guidance Statement speak directly to this matter, so it’s up to us to interpret.
My initial response: The removal of any supplemental information does not require any disclosure; since it is optional, adding or removing supplemental information can be done as you feel appropriate.
I quickly followed this up with: That being said, including an item only when it looks good and removing it when it looks bad, would be, I believe, in conflict with the“spirit” of the Standards. I am not suggesting that this is what you are doing; rather, simply adding further “color” to my answer. The Standards do not specifically speak to items being added, removed, or altered, and so we are left with interpretations. If an item thought to be of value is later determined to not be is clearly justification for its removal; but in reality, any justification can be used.
The Standards are not intended to be prescriptive, though there are times when it may seem they are. In general, they strike a balance between being overly detailed and overly broad. Thus, there are times when one is forced to interpret the rules. Keeping in mind “the spirit” of the Standards can be a helpful guide. One might add this question “what would our clients or prospects think if they found out that we …?” This, too, can help.
Other thoughts or ideas? Please post below; thanks!