GIPS Need to Know List

REQUIRED Disclosures

1. Definition of the Firm
2. Total assets under management (all types)
3. Composite description and creation date
4. Benchmark description
5. Currency used
6. if gross of fees returns are presented must disclose any deductions other than direct trading expenses. 
7. for net of fees returns must: a) disclose any deductions other than trading expenses and investment management fees b) if actual or model investment management fees are used and c) if returns are net of performance based fees 
8. State that composite descriptions are available upon request
9. Disclose valuation & performance measurement policies upon request
10. Disclose presence of leverage, short positions and use of derivatives. 
11. Significant events that would help interpret performance e.g. departure of key investment managers
12. For any non-compliant performance betfore 2000, must disclose period of non-compliance
13. If the firm or composite is redefined, must disclose date, description and reason
14. Must disclose minimum asset level 
15. Must disclose if the name of the composite was changed. 
16. Must disclose relevant treatment of taxes if material and provide benchmark returns net of withholding taxes if available
17. From 1st of Jan 2011, Must disclose any material differences in valuation sources and exchange rates used. (e.g. i used reuters for valuation in one portfolio and Bloomberg in another)
18. Must disclose any conflicts between GIPS and local laws/regulations
19. Must disclose carve out cash policies prior to 1 Jan 2010 (after carve outs were no longer allowed)
20. Must disclose fees included in the bundled fee
21. Disclose any sub advisors and periods they were used from jan 1 2006
22. For periods prior to 2010, must disclose if portfolios were not valued at calendar month end or last business day
23. After 2011, must disclose any material subjective unobservable inputs employed for valuation purposes and any difference in the valuation hierarchy than the one recommended
24. If no benchmark exists, must disclose why
25. If benchmark is changed must disclose date & reason
26. For custom benchmark, must disclose details of the benchmark including components, weights and rebalancing process
27. If the firm has a significant cash flow policy, must disclose how the firm defines it
28. Must disclose if a 3-year annualized ex-post standard deviation for the composite or benchmark is not presented because returns are not available
29. If the firm decides that the 3-year standard deviation is to be excluded because it is not relevant, must disclose why it is not relevant and a description of the alternative risk measure used with reason for its use
30. Must disclose if performance from past firm or affiliation is linked to the performance of the firm

Note valuation hierarchy:

1. Objective unadjusted market prices for similar investments in active markets

2.  Quoted prices for similar investments in non active markets

3. Use market based inputs other than prices

4. Subjective unobservable inputs

RECOMMENDED Disclosures

1. Disclose any material changes to valuation or calculation policies

2. Disclose material differences between the benchmark and the composite's investment mandate, objective or strategy

3. Key assumptions used to value portfolio investments

4. List of other firms contained within the parent company (if relevant)

5. Disclose any subjective unobservable inputs used to value portfolios prior to 2011 (after 2011 mandatory to disclose)

6. Disclose sub advisor used for periods prior to 2006