Q & A Database
The GIPS Standards Q&A database contains questions and answers (Q&As) on various searchable topics that provide additional interpretation on an issue. Q&As are considered to be authoritative guidance and must be followed in order to claim compliance with the GIPS standards.
Content from prior Q&As was included in the GIPS Standards Handbook as much as possible and many Q&As were archived. Change the Status drop-down filter to "Archived" to see the archived Q&As.
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ArchivedEffective: 1 January, 2014 - 31 December, 2019Categories: PortabilitySource: GIPS Executive Committee
Manager A previously worked for Firm X that was not compliant with the GIPS standards. Manager A left Firm X and was hired by Firm Z. Firm Z and Manager A are satisfied that the situation meets all the rules of portability. Can Manager A’s performance history at Firm X become compliant or can it not be used because it is non-compliant?
The performance history can never become “compliant.” Compliance with the GIPS standards can only be achieved on a firm-wide basis. If the manager (or management team) satisfies all the requirements of the Guidance Statement on Performance Record Portability (including bringing all the supporting documentation and records to Firm Z), then Firm Z can use the records to construct a composite track record that can be used. As provided in the Guidance Statement on Performance Record Portability, the important determinant of allowable performance record portability is not a firm’s former compliance with the GIPS standards but whether the acquiring firm continues the original strategy that defined the composite with all of its continuing factors. If all of the portability requirements are not met, the historical performance of the manager cannot be linked to the ongoing performance track record of the firm. The historical performance of the manager can be presented as supplemental information when relevant. Please note one of the rules of portability requires that the decision-making process remains substantially intact and independent at the new firm. If the decision making process is substantially changed, the historical track records of the acquired manager can only be presented as supplemental information and cannot be linked to the ongoing record of the new or acquiring firm.
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