Earlier this year I mentioned that there is no definition of "model fees" in the glossary but that I suspect it means highest actual fee. Well, someone asked if it's possible to use "average fee."
While I suspect not, given the lack of clarity here I'm reluctant to give a definitive "no!" With no explanation as to what "model fee" means, some might suspect they have some leeway.
I will e-mail the GIPS help desk to try to gain some clarity.