some GIPS questions all, supporting, necessary, including

smartpants

Dear all, I am having some questions to seek for your advice:-
(1) Standard 1.A.1 - All data and information necessary to support the firm’s performance presentation including calculations must be stored and maintained.
My question: If I am presenting the past 10 or 20 year performance of a portfolio to client, or the composite returns in marketing materials, then I need to have all underlying data and calculation as supporting for the 10 or 20 year performance?
(2) GIPS verification - Basically it says…. the verification is voluntary.
My question: My understanding is that “Voluntary” is in the sense whether I hired a 3rd party to verify my GIPS or not, my GIPS compliance is not affected (provided that I am sure my firm has filled all GIPS min requirements) because the verification is only voluntary.
How if I do find a 3rd party to verify my GIPS, but the result is not satsifactory. Should I immediately stop to claim GIPS complainces, until the missing part is fulfilled?
(3) Standard 1.A.4 - Portfolios must be valued at least monthly on calendar month-end or last business day.
My question: As I went through all the standards, I could not find any of them to mention the frequency or a specific day required to calculate the portfolio returns. So, with respect to standard 1.A.4, does it mean that the requirement of “on the last business day” and ”on a monthly basis” are ONLY for portfolio valuations? but not implying the portfolio return return calculations?
(4) Standard 4.A.25 - Firms must disclose the use of sub-advisor and the period a sub-advisor was used. (Sub-advisor means to provide investment management, custodial and administrative functions, as well as trading for the clients)
My question: I am having a firm running discretionary in-house portfolios, and also selling external 3rd party funds as an agent. So, should I consider those 3rd party fund houses as sub-advisors? … while I believe that they are performing investment management functions for the funds I am selling to my clients.
(5) Standard 2.A.2 - TWRR must be used to remove the effect of large external cash flows. Subperiod returns must be geog linked.
My question: Just my stupid thinking but still need to clarify. Is there any requiement to clearly define the meaning of “large cash flow” and proper disclosure is required to client for the sake of presenting performance calculations?
(6) Standard 4.A.7 - Policy for valuing portfolio, calculating performance and preparing compliant presentations are available upon request.
My question: What does it mean by “policy” here? Does it mean the detailed method, frequency, dates of portfolio valuation and performance calculations?
Thanks for your help

RMontgomery

just memorize and dont ask questions why

iteracom

1 - yes
2 - you can always claim compliance, but the statement of compliance differs. “Has not been independently verified” vs “has been”. If you try to get verified and fail, yes you need to stop claiming compliance.
3 - returns to be valued using TWRR when large cash flows occur.
4 - no, you’re an agent, you don’t emply them or have any control over their fund mandates.
5 - yes, need to define large, but GIPS imposes no constraints
6 - yes, tell clients “how we do it” for valuing portfolio, calculating performance and preparing compliant presentations