Monday, December 20, 2010

Where does verification and compliance begin and end?

A client of ours asked us the following:

Is their a distinction between being a GIPS® compliant firm and claiming that our performance is GIPS verified? In other words, is the industry standard to have all advertisements and websites GIPS verified if your performance is GIPS verified?

First a firm can claim compliance with GIPS (Global Investment Performance Standards) without being verified. That being said, (a) verification is strongly recommended, (b) there is a new requirement to disclose whether the compliant firm has or has not been verified, (c) the institutional market virtually demands that firms are both compliant and verified, and (d) given the standards' complexity, firms that fail to be verified are probably not compliant.

Firms claim compliance with GIPS; they don't claim that their performance is GIPS verified; it is either verified or is not. Granted, there may be a question about the efficacy of the verification, depending on who did the review, but there still is no "claim" associated with verification.

There is no standard nor requirement to have advertisements or websites "verified." There is no formal review process. We recently offered to review our verification clients' advertisements, because we discovered an error with a firm who was previously not (but subsequently has become) a client, and so thought it worth alerting our clients that we would be happy to do such a review for them, at no additional fee. The reality is that many firms get the advertising guidelines wrong, too, so having a verifier review them isn't a bad idea.

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