Standards research

Much Ado About GIPS Compliance

A practical institutional perspective on GIPS compliance, OCIO performance reporting, comparability, and due diligence.

By Brad Alford, CFANovember 20188 minute read
Much Ado About GIPS Compliance report coverOriginal PDF

Executive summary

Key takeaways

  • GIPS provides a common performance presentation framework, but OCIO customization complicates composite construction.
  • Non-compliance does not prove poor performance; compliance alone does not prove provider skill or client fit.
  • Institutions should understand whose results are included, how dispersion is handled, and whether a record is verified.
  • Performance analysis should be paired with risk, allocation, implementation, objectives, and qualitative due diligence.

01

Why GIPS enters the OCIO conversation

As outsourced chief investment officer relationships grow, institutions need ways to compare providers quantitatively. Global Investment Performance Standards provide a widely recognized framework for calculating and presenting investment results, and traditional asset managers commonly claim compliance.

OCIOs are harder to compare. Client restrictions, alternatives, legacy holdings, implementation decisions, and different objectives can produce very different portfolios within one firm. Highly customized providers face many of the same measurement challenges as non-discretionary consultants.

02

What compliance can tell an institution

GIPS compliance can create discipline around firm definition, composite construction, calculation methodology, disclosures, and presentation. It can reduce the ability to highlight only favorable accounts and can give prospective clients a more consistent record to examine.

Independent verification can provide additional confidence that firm-wide policies and procedures are designed to comply. Fiduciaries should distinguish a claim of compliance from verification and understand the scope of any verifier’s work.

03

What compliance does not tell an institution

Compliance does not make unlike portfolios identical. A composite can still differ from a prospective client’s target allocation, liquidity needs, spending policy, risk tolerance, tax status, or use of private markets. Historical results do not show how a provider will handle a new client’s constraints.

Nor does compliance replace qualitative research. Organization, team stability, investment philosophy, governance, manager access, operational controls, reporting, fees, and conflicts remain central to an OCIO decision.

04

Questions to ask about an OCIO track record

Institutions should ask how the firm is defined, which accounts enter each composite, when accounts enter or leave, whether terminated clients remain in history, how legacy assets are treated, whether performance is gross or net, and which fees are deducted. They should examine dispersion, risk, allocation, and the number and value of portfolios represented.

If a provider is not compliant, ask why, what alternative controls exist, how representative accounts were chosen, and whether underlying data can be reconciled. A thoughtful explanation is more useful than treating the label as a binary pass-fail test.

05

Use performance as evidence, not the entire decision

Performance matters, but it should be interpreted in context. A defensible evaluation connects returns to the provider’s decisions, the risks taken, the client constraints, and the market environment.

GIPS can improve transparency and comparability. The committee’s job is still to determine whether the evidence is relevant to its own mandate and whether the provider has a repeatable process capable of meeting the institution’s objectives.

Important context: This report reflects the market environment and information available at its original publication date. It is educational and does not constitute investment, legal, or fiduciary advice.

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