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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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and this happens in practice. where i work there are tons of composites for gips purposes that are too small/customized to ever be readily marketed (with the proper format of course), but they still exist for the purpose of compliance.

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