The Total Fund and Composite Time-Weighted Return Report is the eleventh section of the GIPS 2020 Exposure Draft.
The Standards here are of similar or the same wording as the associated Firm Standards.
Key Different Standards
The key Standards worth noting here are:
1. Unlike Firms that must present performance for a minimum of 5 years or since inception if younger than 5 years, Asset Owners have a minimum of one (1) year or since inception (11.A.1a).
2. There is also the requirement to show the number of Total Funds or Portfolios in a Composite as of each annual period without meeting the minimum that is required of Firms before they can present (11.A.1g).
3. A key term worth noting here is Net-of-External-Costs Only returns which is distinguished from Net-of-Fees returns (11.B.1 and 11.B.2).
4. The compliance statement for Asset Owners is no different from Firms except in the replacement of Firms with Asset Owners (11.C.1).
5. There is also a requirement that if the compensation of the Asset Owner is like a Firm, then the Asset Owner must disclose its Fee Schedule (11.C.9).
Comments Requiring Feedback
Two comments require your feedback in this section:
2. The second is also with regards to the sunset provisions as also outlined in the Firm section comments mentioned in one above (Comment #41).
How to Send in Your Comments
We have made it easy for you to go through the comments in bite-sizes and to submit your responses quickly by completing comment survey forms covering the feedback areas requested and more. At the end of the commenting period (December 31, 2018), we will compile all the comments received and forward to the GIPS Organization for review.
Sign-up for free on our Composite Insider platform here to do so.
Alternatively, you can send your written responses to the GIPS Organization.
In the next post, we review the changes to Asset Owner Additional Composite Money Weighted Return Report.