The GIPS(R) Standards (Global Investment Performance Standards) require compliant firms to make every reasonable effort to provide prospects with a compliant presentation (¶ I.0.A.9); actually, not just any presentation, but the one(s) that aligns with the prospective client’s objectives. The Standards are kind of silent as to the timing as to when the presentation needs to be provided.

The GIPS Guidance Statement on Supplemental Information states that “[it] does not prohibit firms from preparing and presenting information according to specific requests from prospective clients. However, firms are required to provide a compliant presentation prior to or accompanying any supplemental information.” [emphasis added]

The GS defines “supplemental information” as “any performance-related information included as part of a compliant presentation that supplements or enhances the required and/or recommended provisions of the GIPS standards.” [emphasis added]

This is almost circular logic is it not? By definition, supplemental information accompanies a presentation, so how could it be sent in advance? But does it therefore also mean that if a firm provides performance information, separate and apart from the GIPS presentation, along with the requested details from the prospect, by definition it cannot be “supplemental information,” and is therefore permitted to be sent?

While I recognize that someone may suggest that I am merely being difficult, I do see a hole in this logic. And I realize that one must always be mindful “of the spirit” of the Standards. If a manager isn’t quite sure which presentation to send, or if it’s quarter- or year-end, and the most recent materials haven’t yet been finalized, but the firm wishes to quickly respond to the RFP, and include some preliminary information, with the expectation that presentations will be sent shortly thereafter, is there a problem? I don’t see one.

Bottom line, I see ambiguities in what exists today. I also believe that “the spirit” of the Standards is always something to be mindful of. I realize that many like the Standards to be “black and white” on all matters, but there is often some gray, meaning room for interpretation. At a minimum, the presentation(s) needs to be provided in advance of the prospect becoming a client. And, I would say should be provided once you know which presentation(s) are appropriate. The wording regarding it being sent in advance of or along with supplemental information is a bit confusing, however, and I think can be open to interpretation. What do you think?