Friday, June 12, 2009

Understanding the intent

Patrick Fowler and I are still in Stockholm, having just finished our semi-annual European Performance Measurement Forum meeting, which was deemed quite a success, with much interaction and sharing.

As a result of some discussion I have come to realize that perhaps there's a difference between what is written and what is meant. Unfortunately, a road map might be needed to figure this all out.

Take, for example, the suggested change to not permit a firm to give a GIPS(R) presentation to anyone that is below the minimum. Someone suggested that you can give it to the prospect if they ask for it. What? Where is that stated? The rule is clearly written that you CANNOT give a presentation to someone below your firm's minimum. If the intent was that this applied unless it was asked for, that might be different (although I'd still object to this change, which is misleading as it is written in the disclosure draft, because it suggests that it's currently a recommendation when it isn't!), but that isn't what is written.

Also, what about proprietary assets? The definition includes funds of the firm, owners, and senior management, suggesting that if a senior manager is invested in a mutual fund, they're (a) proprietary and (b) need to be disclosed. We hear that the intent was to focus on seeded assets. Well, if that was what was meant, why wasn't that written? Again, are we to discern this from what we read? Again, in my opinion I'd STILL object to this proposed change but at least the intent would have been clearer.

My criticism shouldn't be misunderstood: the standards are quite complex, and I understand that sometimes our intent isn't clear from what we write (sometimes even my writing is misinterpreted, so I can be accused of calling the kettle black, so to speak). But, I would hope that further clarification would have been given so that the reader understands what is intended. Again, if these interpretations are valid, my opinion wouldn't be altered as I object to both of these proposed changes.

If you haven't yet read the disclosure document but plan to comment, you're running out of time. It's important: please comment!

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