I finally got around to writing up my comments to the draft guidance on supplemental information for GIPS(R) (Global Investment Performance Standards). Since the idea of supplemental information pertains to just about all firms that claim compliance with the Standards, it would therefore be appropriate for all concerned to at least read what’s proposed.

My thoughts on the guidance statement on supplemental information … the short version

For the most part I very much welcome what is being proposed. There was apparently some ambiguity with the prior guidance, and so, at a minimum, that is addressed.

But, saying that, I did feel that there were areas where the guidance could be enhanced. For example, a number of terms are used (e.g., compliant presentation, greater prominence, representative portfolio) that could stand some amplification. The reality is that many of us use these terms, and believe we know what they mean, but perhaps a bit of detail could help.

Need to weed out any potential ambiguity from the guidance statement

I did find one or two areas where there was the potential for confusion, and I brought this out in my comments. For example, I had understood that only supplemental information that is within the corpus, if you will, of the compliant presentation needs to be so flagged. But, this wasn’t as clear as I think it needs to be, so made that point.

How about you?

You have until February 28 to make your comments known. Please review the draft. If you agree with everything, let them know, as they want to hear from you, too!

What about the long version of my comments?

I suspect that my comments, as well as everyone else’s, will be posted on the GIPS website. I haven’t sent them in, yet, because I’m on the road conducting GIPS verifications, but will send them in early next week. If you want to see a copy, just send me a note (DSpaulding@SpauludingGrp.com).