Best Practices for Creating and Maintaining Policies and ... - GIPS

• Have completed or are candidates in the Certificate in Investment PerformanceMeasurement (CIPM) certification program, which emphasizes knowledge ofperformance measurement, attribution, ethics, and the GIPS standards.• Formed a Performance Advisory Council which consists of members fromCompliance, Operations, Risk and Marketing and meets on a regular basis to discussthe firm’s application of the GIPS standards and any other performance-relatedtopics.• Utilizes the firm’s verification service provider for interpretations and applications ofthe GIPS standards.Procedures to consider:• The firm should outline steps taken to ensure awareness of all changes to the GIPSstandards, as well as Guidance Statements, interpretations, Q&As and other clarificationsto the GIPS standards.• The firm should also outline steps taken to ensure awareness of applicable laws andregulations that could impact the firm’s claim of compliance.Helpful hints:• Consider at least two or more of the firm’s staff subscribe to the GIPS Newsletter.• As new guidance and interpretations are issued, consider their impact on the firm’sexisting policies and procedures and adjust accordingly. The GIPS standards areconstantly evolving so a compliant firm’s policies and procedures must continue toevolve as well.• Identify a group or individual at the firm who is responsible for maintaining the policiesand procedures as well as ensuring that all applicable requirements are being followed.• If the firm engages industry experts (either consultants or verifiers) to keep them abreastof the changes to the GIPS standards, this should be highlighted in the firm’s policy.ConclusionSound and practical policies and procedures are the foundation of an accurate claim of GIPScompliance. Creating policies and procedures may require working with several departmentssuch as accounting, compliance, legal, and portfolio management, among others. In addition, it isimportant to keep in mind that firms must have the ability to implement a policy that they decideto document. The firm needs to assess the resources available to them (time, systems, etc.) whendetermining what policies and procedures are feasible for their organization.For more information on the GIPS standards, please refer to www.gipsstandards.org.Best Practices for Creating and Maintaining GIPS Policies & Procedures Page 26