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Compliance Insights for 2024 Reporting

As year-end approaches, compliance with the GIPS standards and SEC Marketing Rule is top of mind for many firms. Our latest update highlights essential strategies for streamlining your tracking and reporting processes for marketing materials, ensuring your net-of-fees returns meet both the GIPS standards and SEC requirements, and conducting effective composite membership and data integrity reviews.

Money Weighted Returns in Excel

If cost was of no matter, then asset managers would all own (fill in the blank with your favorite accounting system). For emerging asset management firms, cost does matter. When managing a start-up commingled fund, an investment firm only needs to calculate a single return stream to comply with best practices in the GIPS® standards. It’s hard to justify a six-figure expense when Microsoft Excel is free, never mind the pitfalls.

SEC Marketing Rule - Hypothetical & Extracted Performance

In this article, we explore the importance of internal policies and procedures—especially as it pertains to hypothetical performance under the SEC Marketing Rule (MR). The adopting release for the MR notes that hypothetical performance can be useful, and it isn’t banned. However, firms not only need to document how they are managing the risk of showing returns with “attention-grabbing power”[1] and ensuring those returns are relevant, they also need to be following those internal procedures.

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