Key Takeaway

• Start with a written decision: Firm, Asset Owner, or dual-role (by presentation context).
• Clarify what you present: strategy/composite/fund vs total fund / oversight reporting.
• Confirm whether you’re making a compliance claim—language creates obligations.
• Identify the report type you must build: GIPS Report vs GIPS Asset Owner Report.
• Decide verification timing early so you build the right evidence trails from day one.

Most organizations don’t choose the wrong GIPS chapter because they didn’t try.

They choose the wrong chapter because the decision gets made informally—inside a performance team conversation—without forcing the people closest to marketing, governance, product, and distribution to answer the same questions in the same room.

This decision tree is designed to do what GIPS itself is trying to do: eliminate ambiguity before it shows up in a report, a pitch, or a verification file.

Use it like a workshop script. Run it once, document the outcome, and treat the result as part of your GIPS scope file.

Step 1: Identify Your Entity Type

Start with the “obvious” question—but answer it in GIPS terms, not corporate branding terms.

A. Are you acting as an investment manager (Firm) for GIPS purposes?

You are likely a Firm for GIPS purposes if your organization (or a defined unit within it):

• provides investment management services, and
• presents performance to prospective clients/investors to win or retain assets.

Remember the core principle emphasized by CFA Institute training and guidance: firm compliance is firm-wide (you can’t comply for only one product or one composite).

That immediately forces a second question: what is “the firm” boundary you intend to claim compliance for?

B. Are you acting as an asset owner (Asset Owner) for GIPS purposes?

You are likely an Asset Owner for GIPS purposes if:

• you manage investments directly and/or through external managers, and
• you are accountable to an oversight body for performance outcomes, and
• you do not compete for business in the way an investment manager does.

This is where many teams should pause: asset owner status doesn’t automatically answer the chapter question if you also have marketed services.

The “dual role” note you must capture in writing

If your organization is an asset owner and markets investment management capability, document that as a dual role upfront. GIPS 2020 anticipates that asset owners who compete for business must comply with the Firms standards in that context.

Step 2: Clarify What Performance You Present

Now move from “what we are” to “what we present.”

Ask this in plain language:

When we show performance, are we saying “allocate to us,” or “this is how our total fund did”?

If you present performance as a manager (Firm-style presentation)

Your materials typically look like:

• strategy performance
• composite track records
• product factsheets
• marketing presentations where performance supports an allocation decision

That aligns with the Firms standards, which include requirements for providing GIPS composite reports (and pooled fund reports, where applicable) to prospective recipients and updating them at least annually for prospects.

If you present performance as an owner (Asset Owner-style presentation)

Your materials typically look like:

• total fund performance reporting
• oversight body reporting packs
• governance dashboards that consolidate internal and external manager outcomes

That aligns with the Asset Owner standards and related guidance about preparing GIPS Asset Owner Reports for the oversight body for the required period.

Step 3: Confirm Whether You Are Making a “GIPS Compliance Claim”

This step is non-negotiable because it determines whether you’re designing internal discipline or external accountability.

Ask two blunt questions:

1. Will we publicly state that we “comply with the GIPS standards”?
2. Are we distributing performance externally in a form that functions like a GIPS Report?

If the answer to either is “yes,” treat the organization as making a compliance claim—and design accordingly.

The trap: “We’re not claiming compliance, we’re just using GIPS methods”

That can be legitimate—until the language drifts.

The moment your marketing materials imply compliance, you have created the risk of a de facto claim without the supporting infrastructure.

And remember: GIPS firm compliance is entity-wide; it cannot be claimed at the composite or product level.

So if your team wants to use “GIPS” in messaging, the scope decision must already be settled and defensible.

Step 4: Identify Which Report(s) You Need to Build

This is where the decision tree becomes almost self-resolving.

If you are a Firm making a compliance claim

Your key output is a GIPS Report (typically a composite report and/or pooled fund report depending on your offerings).

And you must be prepared to distribute that report appropriately to prospective clients/investors—often with specific expectations around updates and making every reasonable effort to provide the report to all required prospects in relevant contexts.

If you are an Asset Owner making a compliance claim

Your key output is a GIPS Asset Owner Report for the oversight body, centered on total fund performance and governance accountability for the required period.

If you are a Verifier (or selecting one)

Your “output” is not a GIPS Report. It’s the verification engagement—performed by a qualified independent third party with required competence and independence expectations.

This is also the point where organizations should document: Are we pursuing verification only, or verification plus performance examinations for particular composites or pooled funds? (The standards distinguish verification of compliance from examination of specific presentations.)

Step 5: Decide Whether Verification Is Needed Now or Later

Verification is not required for compliance, but it’s often expected by serious institutional prospects—and it materially changes your readiness bar.

GIPS recognizes verification as an independent third-party service that provides additional confidence in the organization’s claim, and it sets expectations about verifier qualification and independence.

Decide this like a strategist, not a perfectionist

Use this rule of thumb:

• If you are marketing to institutional prospects, consultants, or cross-border allocators: plan for verification early, even if the engagement happens later.
• If you’re building internal discipline first: design your program as if you will be verified, so you don’t rebuild later.

Because rebuilding the entity boundary and reporting logic after systems and composites are already in place is the expensive kind of learning.

The verifier-lens question that protects you

Before you finalize “later,” ask:

Could an independent third party trace our claim back to documented policies, consistently applied processes, and evidence of report delivery?

If the answer is “not yet,” that’s not failure. It’s a signal to pace the program: scope, policies, data, composites/total funds, reports, then verification.

The decision tree in one page (how you’d summarize it internally)

• If you compete for mandates and market performance → Firms (Chapter A) + GIPS Reports (Chapter D)
• If you report performance to an oversight body and do not compete for business → Asset Owners (Chapter B) + Asset Owner Reports
• If you are testing the claim (as an independent third party) → Verifiers (Verifier standards / Chapter C lens)
• In all cases, design with verification readiness in mind if credibility is a strategic objective.

Next, we’ll stress-test this decision tree against the situations that cause the most real-world debate—wealth models, private markets, group structures, and “we only have partial history.”

Next section: 6. Common Real-World Scenarios (And Which Chapter Applies)

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