For the past eight years, John and Jessica Smith have had their own small financial planning company named JJS Financial in a country where financial regulation is still developing. They have a goal of bringing JJS into compliance with the Global Investment Performance Standards® (GIPS) by January 1, 2005. They begin by researching the history and philosophy of GIPS so they can better understand the requirements for GIPS compliance. As they discuss what they have learned concerning the objective of GIPS with respect to competition among financial firms such as theirs, John expresses his eagerness for the competitive edge GIPS compliance will give JJS. Soon, those of us that are GIPS compliant will have a monopoly, he says. Jessica counters by saying the goal of GIPS is to promote competition, but that will probably benefit small firms like ours that are in developing countries. John and Jessica discuss how they should define themselves as a firm. John says that they only need to define themselves as an investment firm held out to clients or potential clients as a distinct business unit. Jessica says that they must also define themselves as being registered with the appropriate national regulatory authority overseeing the entity's investment management activities. John and Jessica begin compiling and computing the data needed for GIPS compliance. They choose to report annual returns for all years and the cumulative returns for composites and benchmarks for all periods. In computing past returns as well as future returns, they choose to use accrual accounting for fixed income securities but not for equities. Other measures they compute are the dispersion of individual component portfolio returns around the aggregate composite return as well as the number of portfolios and amount of assets in the composite and the percentage of JJS's total assets represented by the composite at the end of each period. As John and Jessica compile the data, they realize that they can satisfy GIPS requirements for the past five years, but they cannot do so for years prior to that. John says they can link non-GIPS-compliant performance to their compliant history as long they disclose the periods of non-compliance with an explanation of why the presentation is not GIPS compliant. Jessica says this will not be sufficient since only the previous five years will be in compliance. Finally, they must decide on a performance compliance statement. John proposes: In this statement, JJS Financial has used the CFA Institute® guidelines outlined in the Global Investment Performance Standards (GIPS®). Jessica proposes: JJS Financial has prepared and presented this report in compliance with the Global Investment Performance Standards (GIPS®). As they put the finishing touches on their report, they realize that some local laws may conflict with the GIPS Standards. John says they need to compare the local laws with the GIPS Standards to make sure there are no conflicts and if there are to change their report to meet the requirements of the local laws and make full disclosure of the conflicts. Jessica disagrees and says if there is a conflict between local laws and the GIPS Standards that the GIPS Standards should be followed. |