Key Takeaway

• Sequence matters: scope → policies → data controls → structure → reports → delivery evidence → readiness.
• Build a minimum viable compliance engine first; templates come after decisions and controls.
• Run a dry cycle: generate reports, approve, deliver, and test evidence trails before external release.
• Create a verifier file early (scope memo, policies, logs, versions) to reduce key-person risk.
• Verification readiness is a discipline, not a last-minute project.

If you’ve ever watched a GIPS project stall, it usually stalls in one of two places:

1. Scope never gets finalized (so everything downstream is built on sand), or
2. Evidence never gets built (so the organization can’t confidently stand behind its own claim).

This roadmap is built to avoid both.

Think of it as a practical sequence that turns “We want to be GIPS compliant” into a program that is actually defensible—internally, externally, and (when you’re ready) under verification.

Phase 1: Scope and Role Clarity (Weeks 1–2)

1) Lock the “GIPS identity” in writing

Your first deliverable isn’t a composite list. It’s a one-page decision memo that states:

• Are we operating as a Firm, an Asset Owner, or both depending on the audience?
• If both, what performance presentations fall under each role?
• Who approves this decision (title + function, not just a name)?

This memo becomes your anchor document. It prevents “chapter drift” later.

2) Define the complying entity boundary (and stress-test it against how you’re held out)

This step is where credibility is won or lost.

A strong entity definition answers:

• What business units are included?
• What products/strategies are included?
• What regions/branches are included?
• If a group structure exists, what’s included vs excluded—and why is that not misleading?

Don’t let the org chart decide this alone. Pull in someone who owns the public story (BD/marketing), someone who owns governance (compliance/legal), and someone who owns operations (finance/performance).

3) Decide your “effective compliance date” strategy

Most organizations underestimate how much time gets burned debating history.

Set a clear strategy for:

• how far back you will build compliant history, and
• how you will handle periods where data is incomplete.

If you can’t support older periods with consistent policies and evidence, don’t force it. Build from a defensible start date.

Phase 2: Build the Compliance Engine (Weeks 3–8)

4) Write the minimum viable policies and procedures (version 1.0)

This is the engine room. Keep it lean but real.

At a minimum, your policy set should cover:

• Valuation policy (sources, hierarchy, frequency, overrides, who approves)
• Performance calculation policy (methodology, frequency, treatment of fees/cash, error correction)
• Composite/total fund construction policy (eligibility, inclusion timing, rebalancing, exclusions)
• Report preparation policy (templates, disclosures control, sign-offs, version control)
• Record retention and evidence (what you keep, where, for how long)

Your goal is not a perfect manual. Your goal is a manual that prevents improvisation.

5) Fix data reality early (before you format anything)

GIPS projects fail quietly when teams build templates on top of messy feeds.

Do a structured “data truth” check:

• Do we have complete valuation and return inputs for every portfolio/account/fund in scope?
• Do we have fee schedules and fee treatment clearly mapped?
• Do we have benchmark histories where required?
• Do we have corporate actions, cash flows, and pricing sources documented?

If you’re a firm, this is also the moment to confirm you can identify all discretionary portfolios that should be included in composites—consistently and completely.

6) Build your structure: composites (firms) or total fund + segments (asset owners)

This is where your “chapter choice” becomes tangible.

• Firms: build composites that reflect how strategies are marketed and managed, and document eligibility and inclusion rules.
• Asset owners: define the total fund and the building blocks (segments, sleeves, external manager structures) that make total fund reporting coherent and repeatable.

The key is repeatability: if your best performance analyst is on leave, someone else should still be able to reproduce the result from policy + evidence.

Phase 3: Reporting and Distribution Discipline (Weeks 9–12)

7) Build the report set you will actually deliver

Don’t build ten templates “just in case.” Build the ones your role requires:

• Firms: the relevant GIPS Report(s) you’ll provide to prospective clients/investors (composite and/or pooled fund reports depending on offerings).
• Asset owners: the GIPS Asset Owner Report you will provide to the oversight body.
• Both (dual-role organizations): two distinct report streams, clearly separated by audience and purpose.

8) Implement distribution proof (the credibility layer most teams skip)

This is where “fairness” becomes operational.

Set a process that captures:

• who received which report version,
• when they received it,
• through which channel,
• and who approved the report for release.

This is not bureaucracy. It’s evidence.

If you ever pursue verification, this record becomes part of your readiness story.

9) Run a “dry distribution” and do a red-team review

Before you send anything externally, do one full rehearsal cycle:

• generate the report
• run internal approvals
• distribute to a test recipient group
• verify the distribution record trail
• review the language and disclosures for consistency and clarity

Then do a red-team review: have someone who was not involved in drafting try to interpret your claim and your scope. If they misunderstand it, prospects will too.

Phase 4: Verification Readiness and Timing (Month 4 onward)

10) Decide verification timing based on market expectations (not internal comfort)

Verification isn’t a moral badge. It’s a strategic choice.

You’ll usually want to accelerate verification if:

• you’re pitching institutional prospects, consultants, or global allocators, or
• you operate in a market where credibility infrastructure is a competitive differentiator.

If the business case is strong, don’t wait until everything is “perfect.” Build a clean evidence trail and engage a verifier once the system is stable.

11) Create a “Verifier File” (even if verification is later)

This is one of the most practical discipline tools you can adopt.

A verifier file is a structured folder (physical or digital) containing:

• the scope memo (chapter decision + entity definition)
• policies and procedures (current and historical versions)
• composite/total fund structure documentation
• report templates and released report versions
• distribution logs / oversight delivery evidence
• change logs (what changed, why, who approved)
• sample portfolio/fund support files (valuation, cash flows, fees, benchmarks)

Even if you never pursue verification, this file improves governance, reduces key-person risk, and makes your claim more defensible.

A realistic timeline (for most firms and asset owners)

• Weeks 1–2: scope and role clarity, entity definition
• Weeks 3–8: policies + data + composite/total fund build
• Weeks 9–12: report build + distribution discipline + dry runs
• Months 4–6: stabilize, refine, then verify when strategically relevant

Some organizations move faster. Many move slower. The difference is rarely “capability.” It’s whether scope and evidence discipline were treated as first-class work, not side work.

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