As noted last week, firms that comply with the Global Investment Performance Standards (GIPS(R)) are now given the opportunity to no longer disclose composite name changes when they are deemed to be no longer "relevant and meaningful."
I think it's fair to interpret from this that such a test can be applied to other "required" disclosures, too. Although there is no conditioning language embedded within the Standards, given that such leeway has been permitted here, it seems to be a logical step to extend the same test to other disclosures; wouldn't you agree? And so, if a firm feels that the departure of the CIO (Chief Investment Officer) 13 months ago is no longer relevant and meaningful, they can stop disclosing it, as well as changes to the composite's strategy, and other things.
Despite the fact that these changes were introduced through a Q&A, I welcome them. It appears that the GIPS EC has decided that the sunset rules are flexible and in the hands of the firm. I think clear wording to this effect should be provided, to ensure that this interpretation is correct. Rather than stipulate that certain disclosures have to stay for one, two, five, ten years, by attaching the "relevant and meaningful" conditioning language, it appears that firms can choose when to discontinue their appearance. I believe that in addition, anytime a disclosure is removed, that its removal be documented, so that the verifier (and probably anyone else) can have a look.
Perhaps a Guidance Statement on Sunset Provisions would be a good idea ... I'd welcome that, too.