GIPS 2010 ... when do we have to comply?

It is becoming increasingly obvious that there is still confusion regarding GIPS(R) 2010, which went into effect on January 1, 2011; just yesterday I got a call from a verification client who wanted to make sure she was fully prepared for my upcoming visit. Any firm that claims compliance with the Global Investment Performance Standards must comply with these changes; but as of when?

It occurred to me that this might help:

• published date: 2010; thus, the name "GIPS 2010," because the revision was published in the year 2010.
• effective date: 2011; this is the date the standards went into effect. The problem is understanding what this means. I think perhaps a better term, never previously revealed is:
• compliance date: the date a firm must comply with the new provisions. And what is this date? It depends!

It depends? Yep! It's not a fixed date, per se, but rather a date which is tied into what you're actually reporting. The moment you begin to reflect any 2011 returns in your composite presentation, you must comply with the new rules. And so,

• if you report monthly returns in your presentations, then in February when you report the returns for January you need to comply,
• if you don't report monthly returns on your statements but do report quarterly, then in April when you report on your first quarter 2011 results, you need to be compliant,
• and, if you don't report monthly or quarterly, but only annual figures, then in January 2012 when you report on the year 2011 returns, you will need to comply.

 Hope this helps!