The U.S. Security & Exchange Commission’s Marketing Rule has imposed several changes to the way performance is reported. For example, previously, GIPS® reports were not considered advertisements; they now are, which means they must conform to this rule. One of the requirements is that if performance is shown using gross-of-fee returns, it must also be shown net-of-fee. A question that has surfaced is whether performance attribution needs to be calculated net. This article proposes that this is not necessary. This is based principally on the contention that attribution does not qualify as performance.

Calculating Net Performance Attribution: Why It Isn't Necessary
David Spaulding, DPS, CIPM, TSG