Performance Perspectives Blog

What happens when you don’t follow the rules???

by | Apr 10, 2013

Often, firms and individuals who don’t behave in accordance with rules, regulations, or standard practices, somehow get away with it. There’s no way to tell how often this happens, though we know it does.

But, there are times when you they caught, and this can be a problem.

Last week, the U.S. Securities & Exchange Commission (SEC) filed an action against ZPR Investment Management, Inc., regarding their advertising practices. They specifically reference conflicts with the Global Investment Performance Standards’ (GIPS(R) advertising guidelines.

While there is no requirement for a verifier to look at their client’s advertising materials, most verifiers, like TSG, I’m sure, will be happy to do so.

Most firms have their CCO (Chief Compliance Officer) review and approve advertisements. But unless he/she is familiar with the GIPS rules, things can be left out. I think it would be a great practice to add your verifier to the process, whenever your ad references GIPS or includes performance figures. Oh, and in case you didn’t know this, your website is an advertisement, too!

p.s., if you read the SEC document you’ll see ZPR’s former verifier referenced. I want to make it perfectly clear that there is no suggestion whatsoever that the verifier did anything wrong.

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