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simple GIPS question (hopefully)

Standard 3.A.1 All actual, fee-paying, discretionary portfolios must be included in at least one composite.
Fair enough. Then:
Standard 3.A.9 If a firm sets a minimum asset level for portfolios in a composite, the minimum must be applied consistently.
So what happens if the firm has a handful of really small accounts which are fee-paying and discretionary, but unsuitable based on size for any of the composites? Must the firm establish another set of composites to accommodate the small accounts?

yes, don’t be shy to establish any number of extra composites, these new composites should probably no set a minimum asset level to sweep up the tini-tiny ones.

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Q’s are pretty strong on the “All fee paying must be included” part of GIPS, so I would go with this one if in doubt. cookthebooks has a good solution I guess

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