The Analyst's Path

GIPS disclosure requirements

The GIPS disclosure requirements are the items a compliant presentation must state alongside its return table. A compliant presentation is a return table plus a page of disclosures, and it is the disclosures (not the table) that carry most of the standard's actual protection. Each one exists to close a specific, historically real abuse, such as silent benchmark-shopping or a gross figure standing in for the net one.

4 min readPart of GIPS & Global Regulatory Frameworks (SEC/SEBI/FCA)Open in course mode

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A compliant presentation is a return table plus a page of disclosures, and it is the disclosures (not the table) that carry most of the standard's actual protection. Every row below is required (subject to the standard's own current exceptions and thresholds, which move; confirm the live list at gipsstandards.org), and every row exists to close one specific, historically-real abuse.

What must a GIPS presentation disclose?

Required disclosureThe specific abuse it closes off
Definition of the firmSets the boundary of what "compliant" even covers, without it, a subsidiary could claim compliance while a related, worse-performing business sits invisibly outside the claim.
The composite's investment mandate, objective, or strategyComparability requires knowing what you're comparing; a vague description lets a composite's actual holdings drift while its name and history stay put.
Benchmark description, and any change to it, with the datePrevents silent benchmark-shopping, swapping to an easier index after a weak stretch and leaving no trace of the swap.
Composite creation date, if different from its inception (track-record start) dateSeparates real-time-tracked history from backfilled history, tells you how much of an impressive early run was recorded as it happened versus assembled afterward.
List of composite descriptions available on requestShows the firm is not hiding a menu of weaker composites you would never think to ask for by name.
Fee schedule, and whether the return shown is gross or net of feesNet is what a client actually keeps; without this label, an eye-catching gross figure can silently stand in for the number that matters.
Use of a model (hypothetical) fee versus actual fees charged, where net returns are shownA model fee can be set lower than any real client pays, flattering a "net" figure everyone assumes is real.
The currency used to express performanceFX translation alone can manufacture or erase several points of apparent return across a cross-border comparison.
The internal dispersion measure used, and that dispersion is not required below six full-year portfoliosTells you whether the return is what most clients actually experienced, or an average hiding a wide spread, and the six-portfolio floor tells you when a composite is too small for the statistic to mean anything.
Three-year annualised ex-post standard deviation of composite and benchmark, for periods ending on or after 1 January 2011 (AA1.03 §8, arithmetic not repeated here)Lets a reader see, side by side, whether outperformance came bundled with extra volatility.
Whether non-fee-paying portfolios are included, and what percentage of composite assets they representGuards against a composite quietly flattered by accounts carrying no fee drag.
Any minimum asset level excluding smaller portfolios, and its valueWithout disclosure, a firm could quietly move the floor to exclude whichever small accounts are currently dragging performance down.
Material use of leverage, derivatives, or short positions, where not inherent to the stated strategyTwo composites with identical headline returns are not comparable if one took materially more structural risk to get there.
Any known, material inconsistency in exchange rates or accounting basis across portfolios in the compositeStops an unremarked mix of valuation bases from quietly distorting a composite's apparent consistency.
Any period the firm's record does not comply with GIPS, with datesPrevents a firm claiming compliance for its whole history when only part of it actually meets the standard, silence would otherwise imply the entire history is clean.
Whether the firm has been independently verified (and for what period), and whether a performance examination has been performed for this specific compositeTells the reader exactly which of the assurance products, if any, actually stands behind this number.
The compliance statement itself, in the standard's required form (see the claim of compliance)The single sentence that converts everything above from a marketing adjective into a formal, falsifiable claim.

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Part of the course

This page is part of GIPS & Global Regulatory Frameworks (SEC/SEBI/FCA) (ES1.02), in Phase 12: Finance Plus, AI and the quant-code track. The module's flashcards and its quiz are in the app.