GIPS® Tips

Experience “White Glove” GIPS Standards Verification With TSG
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Partnering with us means gaining access to a team of seasoned GIPS specialists dedicated to delivering unparalleled service and exceptional value. Whether you’re seeking a new verifier, preparing for your initial verification, or just starting to explore GIPS compliance, TSG is the best choice.
Why Choose TSG?
Unmatched Expertise: Our experienced team brings unmatched proficiency in the GIPS standards, ensuring thorough and efficient (not “never-ending”) verifications.
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TSG Milestones

The Journal of Performance Measurement®
This month’s article brief spotlights “Generalized Multi-Level Performance Attribution – Framework and Model Construction” by Erik Lundström, Ph.D. and Marcus Hedbring. It was published in the Winter 2025/2026 issue of The Journal of Performance Measurement. You can access this article by subscribing (for free) to The Journal (link here).
We present a framework for the construction of consistent multi-level performance attribution models setting out to explain return differences between generic asset portfolios. We address functional and conceptual shortcomings of prevailing standard approaches, facilitating prospects for seamless programmatic implementations. In particular, we introduce the new s-return and s-contribution model parameters to mitigate the problematic standard dependency on not always well-defined returns. We establish a model construction methodology based on the concepts of external and internal effects, constituting generalizations of standard selection, interaction and allocation effects, to be associated with the external and internal nodes of the assumed decision hierarchy tree. We note that explicit attribution models can be defined via the choice of external effects, and we study a generic class of models parametrized by the extent to which the interaction effect, in addition to the selection effect, is included within the external effect definition. Besides encompassing the commonplace full and none inclusion models, we find the golden mean of including half the interaction effect of particular interest thanks to its symmetric portfolio-benchmark treatment. Moreover, we discuss how the choice of model parameters can impact the analysis outcome, highlight the centrality of the assumed decision hierarchy, and stress the importance of a consistent assignment of node individual return contributions and weights. Throughout, we introduce carefully designed quantities and conventions along with an efficient and intuitive notation suitable for multi-level performance attribution modeling.
PUZZLE TIME
Reader Submission from William Little: I noticed that in the Performance Perspectives newsletter you have a puzzle time segment. May I suggest a performance question which I think will be of interest to the performance community. It features a ‘Gap year’ which was briefly examined in previous Performance Perspectives.
Last Month’s Puzzle:
A train leaves NYC for Chicago, traveling at the rate of 75 miles an hour. Another train leaves Chicago for NYC an hour later, traveling at the rate of 50 miles per hour.
When the two trains meet (cross each other), which one is nearer to NYC?
Solution
At the moment the two trains meet and cross each other, they are in the same location. Therefore, they are both at the exact same distance from NYC.
Congratulations to: Anthony Howland, Stephen Campisi, Andrew Tona, and John D. Simpson for submitting the correct solution.
Upcoming Webinars / Surveys
From Back Office to Best Practices: Sean Gilligan on GIPS Compliance and Performance Communication
TSG Performance | TSG Time with Pat & Doug, Episode 38
In Episode 38 of TSG Time, hosts Pat Fowler and Doug Spaulding sat down with Sean Gilligan, founder of Longs Peak Advisory Services, to discuss the challenges of GIPS compliance, performance reporting, and communicating investment results effectively. With more than 25 years in the investment industry, including two decades focused on performance measurement and GIPS standards, Sean shared lessons from building a firm dedicated to helping investment managers navigate these complexities.
Sean’s path into performance measurement began while studying at Pace University, where he worked at an investment firm that emphasized AIMR compliance, the precursor to the GIPS standards. After roles in trading and portfolio accounting, he joined a CPA firm specializing in GIPS verification, eventually becoming a partner. During that time, he frequently saw firms struggle to prepare for verification because they lacked the internal resources or specialized expertise needed to address compliance challenges.
To help fill that gap, Sean founded Longs Peak Advisory Services in 2015. The firm works with investment managers on GIPS compliance and performance reporting, while also helping clients present their results more effectively through materials such as fact sheets and pitch books. Sean noted that maintaining a strong client focus has been central to the firm’s growth.
When asked where firms most often struggle with GIPS compliance, Sean pointed to data challenges. Firms managing large numbers of separate accounts must ensure that portfolios are included in the correct composites for the correct time periods, which can require extensive historical analysis. He also noted that new OCIO guidance introduced in 2025 has added complexity for some organizations as they adjust composite structures and disclosures.
Beyond compliance, Sean emphasized the importance of communicating performance clearly. Investment firms often present statistics that resonate with technical experts but may not connect with the intended audience. Institutional investors may expect detailed analytics such as attribution analysis, while individual investors may benefit from simpler explanations. Developing tailored marketing materials for different audiences can make performance reporting far more effective.
Looking ahead, Sean believes artificial intelligence could significantly influence performance measurement by enabling deeper analysis of investment decisions across large datasets.
He also reflected on lessons from the SEC’s enforcement action against F-Squared Investments, which highlighted the importance of strong quality control and clear disclosure when presenting performance results.
To hear the full conversation, listen to Episode 38 of TSG Time wherever you get your podcasts or visit tsgperformance.com/podcast.
Institute / Training
Inside the Institute: A Fresh Perspective
Institute.TSGperformance.com
Investment performance professionals face rising demands: more data, more scrutiny, and a need to explain outcomes clearly to stakeholders. Whether you’re responsible for performance reporting, risk oversight, attribution analysis, or standards compliance, the Institute of Performance Measurement gives you tools you can use on Monday morning.
Choose from foundational courses that build your core skill set, specialized training in attribution and fixed income analysis, or hands-on Python programming built for real-world performance tasks. You’ll learn from experts with decades of experience, work through practical examples, and gain confidence in areas where precision matters most.
And with on-demand access, you learn at your own pace, on your own schedule. If your goal is to master performance measurement fundamentals, advance your career, or elevate your team’s capabilities, these courses are designed for you.
Overview of Courses at the Institute of Performance Measurement
The Institute offers a range of on-demand, practical training programs geared to investment performance professionals. Students can learn at their own pace, deepen technical skills, and gain real-world tools for calculating, explaining, and improving performance.
Core Offerings:
Free Course
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Masterclass on the GIPS® Standards for Asset Owners – A single-lesson introduction to applying the Global Investment Performance Standards from the asset owner’s perspective.
Foundational and Specialty Courses
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Fundamentals of Performance Measurement (5-module bundle) – A comprehensive program covering rates of return, benchmarks, performance attribution, risk concepts, and GIPS standards. Ideal for newcomers or as a refresher.
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Performance Measurement Attribution (4-module bundle) – A focused deep dive into attribution analysis, including equity, fixed income, multi-level, and multi-period attribution techniques.
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Python for Performance Measurement (32 lessons) – Practical Python training tailored to performance professionals, including data manipulation, visualization, and coding exercises relevant to returns, risk, and GIPS calculations.
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Fixed Income Attribution (3 lessons) – Concentrated training on fixed income attribution methods, bond valuation, yield curve analysis, and several established attribution models.
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Conference Recordings (PMAR North America & PMAR Web) – Collections of sessions and insights from past PMAR events, bridging performance measurement with broader industry trends.
Modular Add-Ons
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Smaller, focused modules on individual topics from the fundamentals curriculum such as risk measurement, GIPS concepts, rates of return, and performance attribution fundamentals.
Issue Contents:
GIPS 2030
The Voice
New Jersey, like Rodney Dangerfield, Gets No Respect
By David Spaulding, DPS, CIPM
While it’s true that I no longer live in the Garden State, it still holds a special place in my heart. My late wife and I were both born in Philadelphia, Pennsylvania, and during the course of our nearly 48-year marriage, lived in four different states (OK, HI, MD, and NJ), and spent the longest time (over 30 years) in NJ. And while our sons were born in OK and MD, our three grandchildren were all NJ-born. Plus, TSG’s headquarters are in NJ.
For decades I’ve known that New Jersey gets no respect. Just a few examples:
- While there are two professional (as in, NFL, or National Football League) teams that play in NJ, they both carry “New York” in their names, not “New Jersey.” Of course, I am speaking of the Giants and Jets. Given the way they’ve been playing, perhaps it’s a good thing they’re not associated with NJ, but it’s still disrespectful to have teams that have played in NJ for a very long time failing to identify with the state in which they play.
- This carries over to announcers, who, when “calling the games,” may tell viewers that they’re in New York, when, in reality, they’re in New Jersey.
- There are three states that have “New” in front of them: New York, New Hampshire, and New Jersey. But only one gets its name shortened: New Jersey often goes by Jersey. Is this disrespect? Can’t say for sure, but it might border on it.
- What TV shows have been associated with New Jersey?
Well, there’s the Sopranos, about the underworld, the mob, the Mafia: take your pick.
And, of course, Jersey Shore, where some of the main characters weren’t even from NJ.
- I recently read, for the second time, Amor Towles The Lincoln Highway, which I’ll do a review on in the near future. In it, there’s only one state that gets disrespect, and it’s New Jersey. And Mr. Towles isn’t satisfied with bashing it once; he does it twice:
“I’d start with Sarah, since Hastings-on-the-Hudson is a shorter ride and has the added benefit of not being in New Jersey.” [page 448]
“When we were driving through ‘Why-would-anyone-on-God’s-green-earth-live-here, New Jersey,…’” [page 527]
Mr. Towles is from Boston, so why he elected to bash NJ is unknown, other than others do, as well, so why not?
It was this that motivated me to pen this piece.
The comedian W.C. Fields was known for bashing the city of his birth (and mine), Philadelphia. But the list of those who bash NJ is probably endless.
So, have I made my point? NJ gets no respect.
Quote of the Month
“I get no respect. The way my luck is running, if I was a politician I would be honest.”
―
“For as this appalling ocean surrounds the verdant land, so in the soul of man there lies one insular Tahiti, full of peace and joy, but encompassed by all the horrors of the half-known life.”
― Herman Melville, Moby-Dick
That’s a Good Question
“The SEC Marketing Rule requires us to have policies and procedures in place to ensure we only provide hypothetical performance to individuals who are qualified to receive it; that they will understand what it is and have the resources to interpret it. Any suggestions?”
Response from David Spaulding, DPS, CIPM
Yes. I suggested this to a client who was facing the same situation: “Where our marketing materials include hypothetical performance, we ensure that recipients are qualified to read it. We market to institutions and high net worth individuals. But we don’t assume that the recipients will necessarily be able to grasp what the hypothetical information represents, so we will spend time with each, going over the material, explain our assumptions, and asking if they have questions, before actually giving them the materials.”
Please note that your CCO (Chief Compliance Officer) and/or outside counsel should “sign off” on whatever language you incorporate. If you’d like to share what you have, please do so. One thing we know: the SEC is quite sensitive about advisors who provide hypothetical performance to individuals who lack the knowledge and resources to properly / fully understand what is being shown.
Compliance Corner
How to use AI to help you avoid a huge fine from the SEC
By David Spaulding, DPS, CIPM
Pass your firm’s URL to an AI tool like ChatGPT and ask “are there any references to hypothetical performance, model returns, back-testing, or back-tested performance.” If you find any, remove them, post-haste.
Several SEC-registered firms have received hefty fines for having such documents on their website.
The SEC’s Marketing Rule has an entire section devoted to this topic. This is a hugely serious matter. Take action now, to avoid problems later.
No one likes the embarrassment of being cited and fined.
GIPS 2030
Looking Ahead to the Next Version of the Global Investment Performance Standards (GIPS®)
As the investment industry continues to evolve, so must the GIPS standards. To support ongoing dialogue and thoughtful progress, we’re continuing to feature proposed changes to the next version of the GIPS standards.
Each month, we highlight a specific area where clarification, alignment, or modernization could help the Standards better reflect today’s regulatory environment and industry practices. Our goal is constructive discussion, grounded in real-world application and the shared objective of promoting fair representation and full disclosure.
We also invite readers to submit topics they would like us to explore in future issues. If there’s an area of the Standards that you find challenging, ambiguous, or ripe for improvement, we’d love to hear from you.
This Month’s Topic: Reverse the Mandatory Composite Structures
By David Spaulding, DPS, CIPM
Reverse the mandatory composite structures outlined in the OCIO guidance, and give OCIOs the same freedom other managers and asset owners have in determining what their composites should look like.
We look forward to continuing this series and to engaging with the community on how the GIPS standards can continue to evolve. If you have a topic you would like us to address in a future issue, please reach out as we welcome your ideas and perspectives.
Industry Dates and Conferences
What to Expect From TSG in 2026
As we head into 2026, TSG is expanding its platform of events, research, and industry resources designed to support performance, attribution, risk, and GIPS® professionals across the globe. The newly released 2026 Partnership Opportunities outline a robust lineup of conferences, forums, research initiatives, and media channels that continue to connect practitioners, asset owners, consultants, and technology providers in meaningful ways.
TSG 2026 Events Calendar
| Date | Event | Location |
|---|---|---|
| April 22 | Asset Owner Roundtable (AORT) – Spring | Montreal, QB, Canada |
| April 23–24 | North American Performance Measurement Forum | Montreal, QB, Canada |
| May 20 | Data Analytics & Performance Measurement Networking Event | Boston, MA, USA |
| June 10–11 | PMAR North America | New Brunswick, NJ, USA |
| June 18–19 | EMEA Performance Measurement Forum | Milan, Italy |
| September 16 | PMAR Europe | London, England |
| October 22–23 | EMEA Performance Measurement Forum | Prague, Czech Republic |
| November 18 | Asset Owner Roundtable (AORT) | San Diego, CA, USA |
| November 19 | North American Performance Measurement Forum | San Diego, CA, USA |
| TBD | Data Analytics & Performance Measurement Event | Amsterdam, Netherlands |
| TBD | Data Analytics & Performance Measurement Event | Dubai, UAE |
Mark Your Calendars! Let’s make 2026 a year to remember.
For information on the 2026 events and partnership opportunities, please contact Patrick Fowler at 732-873-5700.
Potpourri

Article Submissions
The Journal of Performance Measurement® Is Currently Accepting Article Submissions
The Journal of Performance Measurement is currently accepting article submissions on topics including performance measurement, risk, ESG, AI, and attribution. We are particularly interested in articles that cover practical performance issues and solutions that performance professionals face every day. All articles are subject to a double-blind review process before being approved for publication. White papers will also be considered. For more information and to receive our manuscript guidelines, please contact Douglas Spaulding at DougSpaulding@TSGperformance.com.
Submission deadlines
Summer Issue: May 29th, 2026
Fall Issue: October 16th, 2026
For any questions, please reach out to Doug Spaulding at DougSpaulding@TSGperformance.com.
ATTN: TSG Verification Clients
As a reminder, all TSG verification clients receive full, unlimited access to our Insiders.TSGperformance.com site filled with tools, templates, checklists, and educational materials designed to make compliance and verification as easy as possible for you and your firm.
Contact CSpaulding@TSGperformance.com if you have any questions or are having trouble accessing the site.
Book Review
Wuthering Heights: by Emily Bronte
Review by David Spaulding, DPS, CIPM

I am usually reading three-to-four books at a time. I do this for a few reasons. First, it gives me alternatives, should I get to a point in a book that I feel I need a break. Second, since my interests are varied, it allows me to progress across multiple lines at the same time. Third, when I travel, if I complete one book, I can immediately pick up where I left off in a second. A recent trip to Charleston, WV provided this for me, as I managed to finish two books during that trip, one of which I picked up in an airport shop. These books tend to be of different genres (a novel; self-help; a biography, perhaps; something business-related). My tastes are eclectic,* and so having a variety allows me to dabble in various areas at the same time.
One of the books I’m reading at this moment is The Writer’s Chapbook, edited by George Plimpton. Plimpton was the founder and editor of The Paris Review, and this book is a collection of interviews of authors, grouped together by question or topic. One of the authors referenced Wuthering Heights, and knowing (a) it was a classic and (b) I hadn’t read it, I decided to purchase it.
The book is 230 pages long, which is relatively short. After 80, I gave up.
You should know that I try to keep track of the books I read in my journal. So far this year, I’ve read seven. This one won’t make it on the list.
Granted, I could plow through to its end, so that I can (a) mark that “yes, I’ve read this classic,” and (b) add it to my list, but I’d rather spend my time reading something else.
Do you do that? If you start a book and after a bit decide it’s not for you, so you stop? I usually stop sooner, but I continued thinking surely, this will get better, but alas, it didn’t; in my view.
What makes it a classic? I really don’t know. I know there’s a movie out based on it, and my wife suggested we watch it, which we probably will, though given my general distaste for the book, I doubt I’ll enjoy the movie version.
I’ve walked out of about a half-dozen movies. My most memorable was Scenes from a Mall, by Woody Allen, starring Woody and Bette Miller. Within five minutes I knew I couldn’t stand it. This was 35 years ago, and my late wife and I saw it together. I recall we turned to each other and proclaimed that we had to leave.
I value my time. I won’t wait for gas at Costco if I expect the line is too long. To save a couple dollars at the expense of 10-20 minutes of my time just isn’t worth it.
Likewise, sitting through a dreadful movie or plodding through an uninteresting book just doesn’t work for me.
If you’ve read the book and love it, please offer a review for us, and we may include it in a future issue. For me, Emily got more of my time than she should have.
* Eclectic or promiscuous? The book I switched to is Light in August, by William Faulkner (never read any of his work, either; hopefully, I’ll finish this book). In the author’s bio, we find he “took some classes at the University of Mississippi…Mostly, however, he educated himself by reading promiscuously.”
“Promiscuously” seemed like an odd word to use. We (actually, my [new] wife did) found this: “Reading promiscuously is the practice of reading widely, indiscriminately, and without a rigid, curated plan, allowing for a diverse, often disorderly, engagement with books. Advocated historically by John Milton to strengthen truth through exposure to varied ideas, it fosters intellectual, spiritual, and empathetic growth by encouraging readers to engage with, rather than avoid, opposing viewpoints.”
I do think my reading isn’t quite that wide or perhaps random, but, on the other hand, I have been known to pick up a book from a totally different field, because its topic, title, author looked interesting. The piece also referenced a book by Heather Cass White titled Books Promiscuously Read. I added it to my “wish list” on Amazon. I guess this is an example of reading promiscuously, me reading a book on the topic that I had never even heard of before.
BTW, do you read promiscuously?
What a Word
In this section, we will introduce a word we think is a bit unusual or interesting. We hope you enjoy it. And please feel free to send us your suggestions.
- (/kwoʊˈtɪdiən/)
- is an adjective meaning daily, ordinary, or commonplace, often referring to mundane, routine, or expected, everyday events.
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