The overall premise is to address which funds are covered by the guidance, and the requisite marketing obligations with regards to the GIPS standards. Public funds that meet the following three criteria will be covered:
- The pooled fund is broadly distributed.
- There is typically no or minimal contact between the firm marketing the pooled fund and prospective pooled fund investors.
- The firm has the ability to influence the pooled fund’s official documents or marketing materials.
- Does not include hedge funds, private equity funds, real estate funds, etc.
- Does not apply to sub-advisors of funds that do not create or influence the fund documents.
However, after discussion and feedback, a decision was made to push the effective date back to 1 January 2020. The primary reason for this was to match up with the effective date of GIPS 20/20, but there are also considerations for the Safe Harbor provision that must be addressed. While early adoption is encouraged, the delay should come as a relief to any firm that expressed concerns around the Safe Harbor provision. For more information, please visit the GIPS standards website, or contact your verification team with any questions.
For More Information
For more information, please contact Christie Dillard Horsman at (866) 279-0750 or Jason Millard at (541) 292-0001
About the Author
Douglas Finlay, CIPM, is a Senior Principal Consultant with ACA Performance Services, a division of ACA Compliance Group. Douglas joined ACA in 2007 and has worked with over 50 clients including several asset owner clients. Douglas earned his B.A. in History from the University of the South (Sewanee). He also holds an M.B.A. with a concentration in Finance from the University of Tennessee at Chattanooga, where he was awarded the John C. Stophel Distinguished Student Award. He is a member of CFA Institute and the CFA Society of East Tennessee.