Key Takeaway

• GIPS 2020 separates standards for Firms, Asset Owners, and Verifiers, making role clarity unavoidable.
• Chapter choice is more explicit because reporting and verification expectations are organized by intended audience.
• The new structure improves implementation—if you start with the right role and entity boundary.
• GIPS 2020 strengthens consistency around reports, disclosures, and distribution discipline.
• The biggest “change” is practical: chapter selection becomes a defined decision point, not an assumption.

If you learned GIPS through the “old mental model” (one main standard, one set of provisions, then extra guidance for special cases), GIPS 2020 will feel like a structural reset—because it is.

The 2020 edition didn’t just revise requirements. It reorganized the standards around who is doing the presenting and why, and that’s exactly why chapter selection became both clearer and more misunderstood at the same time. (CFA Institute)

The biggest shift: three tailored frameworks, not one “one-size” standard

GIPS 2020 formalized three distinct standards sets:

• GIPS Standards for Firms
• GIPS Standards for Asset Owners
• GIPS Standards for Verifiers

CFA Institute itself teaches the 2020 edition through that three-framework lens. (CFA Institute)

Why that matters for chapter selection

Because the standards now assume you will first answer:

“Which framework applies to the way we present performance?”—and only then go into the detailed requirements.

This is why the “Firm vs Asset Owner” decision is no longer a side note. It’s the doorway.

The Firm vs Asset Owner line is sharper (and it’s behavior-based)

In GIPS 2020, being an “asset owner” in the everyday sense is not the deciding factor. The standards introduce a practical dividing line:

• Asset owners typically present performance to an oversight body (board of trustees, investment committee, similar governance authority). (CFA Institute Research and Policy Center)
• But if an asset owner competes for business, it must follow the GIPS Standards for Firms when competing for business. (GIPS)

That one requirement explains a huge portion of the confusion you see in the market:

“We’re a pension fund / endowment / insurer, so we must be Asset Owner chapter.”

Not always—not if you’re marketing or competing for mandates. (GIPS)

In other words: GIPS 2020 uses “what you’re doing with the performance” as the governing logic, not your label.

Reports became more explicit: what you distribute drives obligations

GIPS has always cared about fair representation. But 2020 tightens the focus by making “reports” a clearer compliance mechanism:

• Firms build and distribute GIPS Reports (e.g., for composites or pooled funds) in connection with marketing and external distribution. (GIPS)
• Asset owners must provide GIPS Asset Owner Reports to their oversight body, and must be able to demonstrate how those reports were provided. (GIPS)

So chapter selection isn’t just “which rules do we like.” It’s:

Which report type are we required to produce—because that reveals the standard set we’re operating under?

This is also why the second test in your outline (“Are you making a compliance claim and distributing externally?”) matters so much. GIPS 2020 makes it harder to be vague about what you distribute and to whom.

Asset owner guidance is no longer “extra”—it’s built in

GIPS 2020 didn’t merely acknowledge asset owners; it built a dedicated standard set around them, including concepts like:

• Defining the asset owner for compliance purposes (the “boundary” problem)
• Treating total funds as central reporting building blocks
• Governance accountability to an oversight body (GIPS)

This is one reason asset owners often feel relief when they switch from “trying to retrofit firm composites onto total fund reporting” to using the Asset Owner provisions properly.

Verifiers got their own standard set (and that changes how you should prepare)

The “GIPS Standards for Verifiers” aren’t just a back-office document for verification firms. They matter to managers and asset owners because they signal what will be tested and how.

GIPS 2020 formalizes that verification (and performance examination) must be performed by a qualified independent third party, and it describes verifier qualification expectations—professional abilities, audit methodology expertise, investment management and performance calculation knowledge, and independence considerations. (Investment Management Association)

Why this affects your chapter selection and scoping early

Because the verifier doesn’t only look at whether you followed a checklist. They assess whether:

• Your defined entity makes sense for your claim (firm definition or asset owner definition)
• Your policies and procedures are structured to maintain compliance
• Your reporting and distribution practices match the framework you claim compliance under (GIPS)

This is where a wrong chapter choice becomes expensive: it tends to surface later, when you’re already deep into implementation—or preparing for verification.

A practical summary of “what changed” that directly impacts chapter choice

If you’re advising a team, here are the GIPS 2020 changes that most directly shape chapter selection decisions:

1. Separate frameworks for firms, asset owners, and verifiers (no more “interpretation gymnastics”). (CFA Institute)
2. Behavior-based rule: asset owners that compete for business must follow the Firms standards when competing. (GIPS)
3. Report-based clarity: asset owners must provide reports to an oversight body and be able to demonstrate delivery. (GIPS)
4. Verifier standards are explicit, making “verification readiness” a design constraint, not an afterthought. (Investment Management Association)
5. The standards emphasize credibility as a market passport—raising the stakes for getting the chapter right before you start building. (GIPS)

When you put those changes together, you get the real takeaway:

GIPS 2020 rewards clarity.

But it punishes assumptions—especially the assumption that “asset owner” automatically means “Asset Owner chapter.”

Next, we’ll lock this down into a clean decision framework: the two tests that determine your chapter—fast, defensible, and verifier-friendly.

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