A "work around" for portability

I had a discussion this week with a firm that is thinking of bringing someone on. That person meets two of the three criteria for GIPS(R) (Global Investment Performance Standards) portability:

• Substantially all the decision makers are coming along
• Will continue to manage in the same way as historically has done

The challenge, which is typical, is records. What to do, what to do?

Fortunately, the manager has access to one or two accounts, meaning access to custodial records. BUT, not enough records for GIPS. This performance can be show as a "rep account," and as "supplemental" to the GIPS presentation. Not ideal, but can be done. With, appropriate disclosures!