Is the sun setting on your disclosures?

The GIPS 2010 Exposure Draft sought to obtain a consensus to build a case to establish sunset provisions for certain required disclosures (e.g., name or strategy changes to composites) for GIPS(R) (Global Investment Performance Standards). And we are aware that some firms have implemented them in their policies. However, just to make it very clear, they do not exist!

While the GIPS Executive Committee hoped to establish them, because of the limited feedback they received, none resulted, none exist. Therefore, any disclosure shown as being required in the Standards is required forever, or until it no longer applies (e.g., if a change occurred for a year that is no longer reported, because it happened more than ten years ago, then one can arguably remove it, but not if that period is still shown on the presentation).

Any verifier who allows their clients to establish sunset rules is, in my view, doing their client a disservice, not a favor, since there is no basis for this. That's my interpretation, but I'm open to others'.