Entries by Kim Cash

Does the New SEC FAQ Impact Your Fund Calculations?

In February, the SEC published another Q&A pertaining to the 2022 marketing rule.  For CCOs working with private funds at firms that don’t claim compliance with the GIPS Standards, you’ll want to check the performance calculation input for the start date of the IRR and make certain the same date is used for both gross and net performance. 

Hypothetical Performance Risk Alerts

These past few weeks, the SEC has charged 10 firms with violating the New Marketing Rule (NMR), and each of the firms charged share a common error: advertising hypothetical performance without establishing and implementing the required internal “policies and procedures reasonably designed to ensure that the performance is relevant to the likely financial situation and investment objectives of the intended audience.”

ESG Disclosure Standards

CFA Institute released third-party assurance standards for firms claiming compliance with its Global ESG Disclosure Standards for Investment Products (the “Standards”). As controversy over the proposed SEC ESG Rule grows, it’s important to understand the CFA Institute’s voluntary framework and assess the benefits of voluntary compliance and assurance on a firm’s investment products, as well as the similarities and differences in proposed regulations.

Year-End Marketing Material Updates

RIAs across the country are preparing year-end 2022 performance presentations, and for most GIPS compliant firms, it’s time to update annual performance on your GIPS Reports.  Or is it?  Below are four timely Q&As as we kick-off annual verifications and performance examinations.