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GUIDANCE STATEMENT ON THE APPLICABILITY OF THE GIPS STANDARDS TO ASSET OWNERS 1

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GUIDANCE STATEMENT ON THE APPLICABILITY

OF THE GIPS STANDARDS TO

ASSET OWNERS

1

WHAT ARE GLOBAL INVESTMENT

PERFORMANCE STANDARDS?

Voluntary standards governing the calculation and

presentation of investment performance based on the

ethical principles of fair representation and full disclosure.

The goal of the GIPS Executive Committee is to have all

firms adopt the GIPS standards as the standard for

investment firms to present historical investment

performance information.

2

OBJECTIVES

Ensure accurate and consistent data

Obtain worldwide acceptance of standards for

calculating and presenting performance

Promote fair, global competition among

investment firms

Promote industry self-regulation on a global basis

3

MISSION

Promote ethics and integrity and instill trust through

the use of the Global Investment Performance

Standards by achieving universal demand for

compliance by asset owners, adoption by asset

managers, and support from regulators for the

ultimate benefit of the global investment

community.

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OBJECTIVES OF THE GIPS STANDARDS

Consistency

Transparency

Disclosure

Comparability

Assessment of

the asset

manager’s

performance

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BENEFITS OF AN INDUSTRY CREATED

PERFORMANCE STANDARD

• Prospective Investors:

- Transparency and confidence

- Ethical commitment - ‘best practice’

professionalism

- Viewed as the norm

• Firms:

- Global passport

- Self regulation

- Enhance internal controls

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BENEFITS OF AN INDUSTRY CREATED

PERFORMANCE STANDARD

• Asset Owners:

- Demonstrates commitment to follow global

industry standard and best practice

- Performance Calculation

- Performance Presentation

- Valuation

- Establishes robust performance policies and

procedures

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BENEFITS OF AN INDUSTRY CREATED

PERFORMANCE STANDARD

• Asset Owners (cont’d):

- Commitment to consistent, transparent, and

comparable methods of calculating and

presenting performance

- Adopt same principles required by external

investment managers

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EVALUATING PERFORMANCE

Is this a good asset manager ?

40

60

80

100

120

140

160

Asset Manager Benchmark

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PERFORMANCE EVALUATION

Who is the better

asset manager ?

Manager A Manager B

5 % 5 %

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THE NEED FOR STANDARDS

Selective time

period presentation

“Cherry picking”

of accounts

Use of model/

back-tested performance

Use of inappropriate

benchmark/index Inadequate disclosures

Why do we need

performance presentation

standards?

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HISTORY OF THE STANDARDS

AIMR-PPS Standards

Standards drafted in 1987 – Adopted 1993

Voluntary, ethical principles

Fair representation and full disclosure

Ensure accurate & consistent data

Promote fair competition

Industry self-regulation

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HISTORY OF THE STANDARDS

GIPS Standards

Initiative began in 1995 – Adopted 1999

US, UK, Switzerland & Japan had well established

performance standards

A global solution was discussed

Promote fair representation & full disclosure

“The Global Passport”

Country Versions of GIPS still existed

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HISTORY OF THE STANDARDS

“Gold GIPS”

Moved to one global standard in 2005

Global solution

Promote fair representation & full disclosure

“The Global Passport”

Full compromise was reached

Country Versions of the GIPS standards were abolished

Committed to reviewing GIPS once every 5 years

HISTORY OF THE GIPS STANDARDS

AND ASSET OWNERS

• GIPS Standards were traditionally designed for

investment managers.

• Asset Owners were also allowed to claim compliance with

GIPS.

- Asset Owners were confused about how to apply

requirements and recommendations that were not

originally designed for them.

• New Guidance Statement provides interpretation on the

requirements and recommendations related to asset

owners.

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HISTORY OF THE GIPS STANDARDS

AND ASSET OWNERS

Entities with discretion over the assets under

management, either by managing assets directly or

having the discretion to hire and fire underlying

investment managers can claim compliance.

Who is considered to be an “asset owner” under the new

guidance statement?

- Entities that manage investments, directly and/or

through the use of external managers, on behalf of

participants, beneficiaries, or the organization itself,

including (but not limited to):

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HISTORY OF THE GIPS STANDARDS

AND ASSET OWNERS

(cont’d)…

- Public and private pension funds

- Endowments

- Foundations

- Family offices

- Provident funds

- Insurers and reinsurers

- Sovereign wealth funds

- Fiduciaries

The term “asset owner” applies to organizations and NOT to individuals.

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HISTORY OF THE GIPS STANDARDS

AND ASSET OWNERS

Why is guidance needed specifically for asset owners?

- Asset owners are typically accountable to an oversight board (e.g., board of trustees) responsible for establishing investment policies and monitoring performance.

- Most asset owners do not have prospective clients.

- Most asset owners do not compete for business.

- Asset owners manage assets to support the mission of an organization.

- Asset owners are often only accountable to their oversight boards.

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HISTORY OF THE GIPS STANDARDS

AND ASSET OWNERS

Why is guidance needed specifically for asset owners?

- Different model from investment managers.

- Investment managers market performance to attract and retain clients.

- Many GIPS provisions relate to marketing to prospective clients and would not apply or apply differently to asset owners.

- Many GIPS provisions are not clearly interpreted for the use of asset owners.

This Guidance Statement addresses these differences and clarifies the appropriate requirements and recommendations.

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HISTORY OF THE GIPS STANDARDS

AND ASSET OWNERS

Asset owners who do not compete for business or

market to prospective clients must follow this Guidance

Statement.

Some asset owners manage assets of other related

asset owners to gain efficiencies and cost savings and

do not compete for business or market to prospective

clients.

- These asset owners must follow this Guidance

Statement.

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HISTORY OF THE GIPS STANDARDS

AND ASSET OWNERS

Asset owners with the authority to compete for business

and market to prospective clients must follow the existing

GIPS Guidance and requirements and would not follow

this Guidance Statement.

- If an asset owner can attract and retain prospective

clients, it adopts the investment manager model and

this guidance is no longer appropriate.

- They may use this Guidance Statement as a helpful

reference for understanding terms within GIPS.

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WHAT IS INCLUDED IN THE GIPS STANDARDS?

The following items are considered part of the GIPS

Standards authoritative guidance and interpretation:

The GIPS Standards

All GIPS Guidance Statements

All Q&As in the GIPS Q&A Database

GIPS Handbook

Any Updates or Clarifications Published by the GIPS EC

and CFA Institute

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PROVISIONS OF GIPS STANDARDS

0. Fundamentals of Compliance

1. Input Data

2. Calculation Methodology

3. Composite Construction

4. Disclosure

5. Presentation and Reporting

6. Real Estate

7. Private Equity

8. Wrap Fee/Separately Managed Accounts (SMA) Portfolios

The GIPS standards must be applied on a firm-wide basis.

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CURRENT GUIDANCE STATEMENTS

Applicability of the GIPS Standards

to Asset Owners

Alternative Investment

Strategies and Structures

Calculation Methodology

Composite Definition

Definition of Firm

Error Correction

Fees Provisions

Impact of Euro Conversion

Performance Examinations

Performance Record Portability

Private Equity

Real Estate

Record Keeping

Treatment of Carve-Outs

Treatment of Significant Cash Flows

Use of Supplemental Information

Verification

Verifier Independence

Wrap Fee/ Separately Managed

Accounts

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RESOURCES

The GIPS standards website:

- Complete List of Guidance Statements

- Q&A Database

- Free Webcasts

- How to Become Compliant

http://www.gipsstandards.org/compliance/Pages/index.aspx

The GIPS standards Handbook

Helpdesk: [email protected]

E-mail Alert List: [email protected]

Twitter: @gipsstandards

Certificate in Investment Performance Measurement (CIPM):

cfainstitute.org/cipm

www.gipsstandards.org

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