January 2010...are you ready?

If you have a copy of the current version of the GIPS(r) standards, you can fairly easily identify most of the planned changes for this coming January. They include the requirement to revalue portfolios whenever large cash flows occur and the need to manage cash separately for any carved-out portion of a portfolio. What you won't find is the requirement to disclose any material changes to a presentation for a minimum of one year.

This requirement was introduced in the revised Error & Correction Guidance statement, which was approved by the GIPS Executive Committee last year. I have commented on this in our newsletter (http://www.spauldinggrp.com/services/resource-center/91-newsletters-pamphlets-a-white-papers.html), but wanted to do so here, too, because of its importance and ease of being overlooked.

Putting aside my disagreements with (a) requirements being introduced in guidance statements and (b) the requirement being introduced without public comment, firms must be aware of this in order to implement it. Essentially the requirement is that if you discover a "material" change, which requires you to make an amendment to a presentation, you must disclose this in the presentation (i.e., you make a correction to a presentation, disclose that this was done).

I heartily object to this requirement and am hoping it will be removed (if you agree, you need to communicate this to the EC in your response to the GIPS 2010 disclosure draft). But in case it isn't removed, then you need to be prepared. Your P&P (policies & procedures) should reflect this requirement.